Fridman, Aven, & Khan Motion For Issuance of Letter of Request For International Judicial Assistance

Case 1:17-cv-02041-RJL Document 90 Filed 08/04/20 Page 1 of 3
UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA
------------------------------------------------------------- X
MIKHAIL FRIDMAN, PETR AVEN, and :
GERMAN KHAN, :
:
Plaintiffs, :
:
Case No. 1:17-cv-02041 (RJL)
v. :
:
BEAN LLC (a/k/a FUSION GPS) and GLENN :
SIMPSON, :
:
Defendants. :
------------------------------------------------------------- X
PLAINTIFFS’ MOTION FOR ISSUANCE OF
LETTER OF REQUEST FOR INTERNATIONAL JUDICIAL ASSISTANCE
Plaintiffs respectfully file this motion asking the Court to issue a Letter of Request for
International Judicial Assistance to the Senior Master of the High Court (Queen’s Bench
Division) of England and Wales, pursuant to the Hague Convention of 18 March 1970 on the
Taking of Evidence Abroad in Civil or Commercial Matters (the “Hague Convention”), 28
U.S.C. § 1781, and Rules 28(b) and 26 of the Federal Rules of Civil Procedure. As set forth in
the accompanying Memorandum of Points and Authorities, the request seeks the oral testimony
of Christopher Steele, Christopher Burrows, Edward Baumgartner, and Sir Andrew Wood and
the production of documentary evidence from Mr. Steele, Mr. Baumgartner, Sir Andrew Wood,
and Orbis Business Intelligence Ltd., each of which is located in the United Kingdom of Great
Britain and Northern Ireland and have information relevant and material to this case for use at
trial. Accordingly, Defendants respectfully request that the Court grant this motion, and order
that the Letter of Request be issued. The Letter of Request and Proposed Order, along with a
Declaration of Alan S. Lewis, accompany this motion.
9700333.3
Pursuant to Local Civil Rule 7(m), on Monday, August 3, 2020 Plaintiffs’ counsel met
and conferred with Defendants’ counsel with respect to the requested relief. Defendants’ counsel
indicated that, while they have not seen the motion papers, they do not oppose the relief
requested, and otherwise take no position on the motion.
Dated: Washington, D.C.

August 4, 2020
Respectfully submitted,
/s/ Kim Sperduto

Alan S. Lewis (#NY0252)
CARTER LEDYARD & MILBURN LLP
2 Wall Street
New York, NY 10005
Tel: (212) 732-3200
Fax: (212) 732-3232
lewis@clm.com
-and-
Kim Sperduto (DC Bar No. 416127)

SERDUTO THOMPSON & GASSLER PLC
1747 Pennsylvania Avenue, NW, Suite 1250
Washington, D.C. 20006
Tel: (202) 408-8900
Fax: (202) 408-8910
ksperduto@stglawdc.com
Attorneys for Plaintiffs
9700333.3
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing was served electronically via
the CM/ECF electronic filing system on all counsel or parties of record this 4th day of August,
2020.
/s/ Kim Sperduto

Kim Sperduto
9700333.3
Case 1:17-cv-02041-RJL Document 90-1 Filed 08/04/20 Page 1 of 47

------------------------------------------------------------- X
GERMAN KHAN, :
:
Plaintiffs, :
:
Case No. 1:17-cv-02041 (RJL)
v. :
:
SIMPSON, :
:
Defendants. :
------------------------------------------------------------- X
PLAINTIFFS’ MEMORANDUM OF POINTS AND AUTHORITIES
IN SUPPORT OF MOTION FOR ISSUANCE
OF LETTER OF REQUEST FOR INTERNATIONAL JUDICIAL ASSISTANCE
Plaintiffs respectfully ask the Court to issue a letter of request for international judicial
assistance to the Senior Master of the High Court (Queen’s Bench Division) of England and
Wales, pursuant to the Hague Convention of 18 March 1970 on the Taking of Evidence Abroad
in Civil or Commercial Matters, 28 U.S.C. § 1781, and Rules 28(b) and 26 of the Federal Rules
of Civil Procedure. The request seeks the oral testimony of Christopher Steele, Christopher
Burrows, Edward Baumgartner, and Sir Andrew Wood and the production of documentary
evidence from Messrs. Steele and Baumgartner, Sir Andrew Wood and Orbis Business
Intelligence Ltd., each of whom is located in the United Kingdom of Great Britain and Northern
Ireland (“United Kingdom”) and have information relevant and material to this case for use at
trial. The Letter of Request sought to be issued by the Court and the Proposed Order accompany
this motion.
I. THE LEGAL STANDARD

1. The Hague Convention Treaty on the Taking of Evidence Abroad in Civil and
Criminal Matters (“Hague Convention”), 23 U.S.T. 2444, T.I.A.S. No. 7444, 28 U.S.C. § 1781,
is an international treaty that provides a mechanism for obtaining evidence from persons and
entities located in a foreign country (documentary evidence and testimony), in which a judicial
authority in one contracting state may request evidence located in another contracting state. Dist.
Title v. Warren, Civil Action No. 14-1808 (ABJ/DAR), 2016 U.S. Dist. LEXIS 201347, *10-11
(D.D.C Dec. 23, 2016) (citing Estate of Klieman v. Palestinian Auth., 272 F.R.D. 253, 255
(D.D.C. 2011)). The United States and the United Kingdom are parties to the Hague
Convention. 1
2. Under the procedures, a U.S. court issues a letter of request which is then
transmitted to the jurisdiction from which a party to a U.S. civil litigation seeks documentary
evidence or testimony relevant to the issues in the U.S. action. See Fed. R. Civ. Pro. 28(b)(1)(B);
28 U.S.C. § 1781. The Hague Convention procedures are “available whenever they will facilitate
the gathering of evidence by the means authorized in the Convention.” Societe Nationale
Industrielle Aerospatiale v. U.S. Dist. Court for S. Dist. of Iowa, 482 U.S. 522, 541 (1987).
Resort to the Hague Evidence Convention procedures is appropriate after examining “in each
case ... the particular facts, sovereign interests, and likelihood that resort to those procedures will
prove effective.” Id. at 544. It has been held that, “[w]hen discovery is sought from a non-party
in a foreign jurisdiction, application of the Hague [Evidence] Convention, which encompasses
principles of international comity, is virtually compulsory.” Tulip Computers Int'l B. V. v. Dell
Computer Corp., 254 F. Supp. 2d 469, 474 (D. Del. 2003).
1
See https://www.hcch.net/en/instruments/conventions/status-table/?cid=82
2
3. In this case, the individuals to be deposed are non-parties to this matter and are
located in a foreign jurisdiction—the United Kingdom—which is a party to the Hague
Convention. Under Federal Rule of Civil Procedure 28(b), a deposition may be taken outside of
the United States, inter alia, “under an applicable treaty or convention” or “under a letter of
request, whether or not captioned a ‘letter rogatory.’” Even in the absence of an applicable
treaty, Rule 28 further provides that the Court may issue a letter of request for a deposition in a
foreign country, “(A) on appropriate terms after an application and notice of it; and (B) without a
showing that taking the deposition in another manner is impractical or inconvenient.” See
Hyundai Motor Co. v. Direct Techs. Int'l, Civil Case No. 1:19-mc-00206 (TNM), 2019 U.S. Dist.
LEXIS 219865, *4 (D.D.C. Dec. 23, 2019) (“the Rule . . . explicitly disclaims any requirement
for ‘a showing that taking the deposition in another manner is impracticable or inconvenient’”)
(internal citation omitted). “Harmonizing that tone, the D.C. Circuit has held there must be
‘good reason’ to deny a party’s request.” Id. at *2 (citing Zassenhaus v. Evening Star
Newspaper Co., 404 F.2d 1361, 1364 (D.C. Cir. 1968)). “[FRCP] 28(b) functions within the
larger discovery framework, outlined in [FRCP] 26, which allows ‘parties to obtain discovery
regarding any non-privileged matter that is relevant to any party's claim or defense.’” Dist. Title,
2016 U.S. Dist. LEXIS 201347, at *12 (internal alterations omitted). A court may not weigh the
evidence that is to be adduced or attempt to predict, whether, in fact, the witnesses will be able to
give the testimony which is sought (id.), however Plaintiffs have nevertheless demonstrated
herein that Messrs. Steele, Burrows, and Baumgartner, Sir Andrew Wood, and Orbis Business
Intelligence Ltd. (“Orbis”), have information relevant to the issues in this Action.
4. 28 U.S.C. § 1781(b) also provides that letters of request may be transmitted
directly from a tribunal in the United States to the foreign or international tribunal, officer, or
3
agency to whom it is addressed and its return in the same manner. Dist. Title, 2016 U.S. Dist.
LEXIS 201347 at *13.
5. As set forth herein, the documentary evidence and testimony sought by Plaintiffs
is relevant to the parties’ claims and defenses in the Action, and this Court should order that this
motion be granted and issue the accompanying Letter of Request.
II. BACKGROUND REGARDING NEED FOR TESTIMONY AND EVIDENCE
6. Plaintiffs commenced this civil action on or about October 3, 2017, alleging that
they were defamed by Defendants’ 2016 publication of statements that accuse Plaintiffs of
bribery and corruption in their relationship with Vladimir Putin and suggest that Plaintiffs
cooperated with a Kremlin-orchestrated illegal campaign to interfere with the 2016 U.S.
presidential election.
7. The defamatory statements were in a two-page memorandum or “report” labeled
Company Intelligence Report 112 (“CIR 112”). 2 CIR 112 was prepared by former British
intelligence agent Christopher Steele after he and the company he co-founded, Orbis, were hired
by Defendants to do so. Mr. Steele prepared at least 15 other memoranda for Defendants, as a
part of that same assignment. Defendants had been engaged by a law firm for the Democratic
National Committee and/or the Hillary Clinton Campaign in 2016 to produce political opposition
research about then-presidential candidate Donald Trump, and Defendants hired Mr. Steele and
Orbis to assist them on that engagement. 3 The memoranda that Mr. Steele drafted and compiled
for Defendants, although written over the course of a six-month period about different subjects,
2
Declaration of Alan S. Lewis in Support of Motion for Issuance of Letter of Request for International Judicial
Assistance, dated August 4, 2020, Exhibit (“Ex.”) L.
3
See Ex. A, attaching excepts from the book authored by Defendant Simpson and Peter Fritsch, Crime in Progress,
Inside the Steele Dossier and the Fusion GPS Investigation of Donald Trump (2019) (“Crime in Progress”) at 56-60
(explaining that Perkins Coie LLP, a law firm that represented the Democratic National Committee and Hillary
Clinton campaign, engaged Fusion in 2016 to conduct research on Mr. Trump).
4
came to be referred to singularly by the media as the “Trump Dossier,” “Steele Dossier” or the
“Dossier” (referred to herein as the “Dossier” or the “reports”).
8. In spite of the Trump-focused nature of the Defendants’ research which was
partially sub-contracted to Mr. Steele, the report containing the statements defamatory of
Plaintiffs (CIR 112) does not mention Mr. Trump or his campaign. Instead it accuses Plaintiffs
of having a corrupt relationship with Vladimir Putin and the Kremlin. Specifically, it defames
Plaintiffs in the following ways:
a. The heading of CIR 112, “RUSSIA/US PRESIDENTIAL ELECTION:
KREMLIN-ALPHA GROUP COOPERATION,” coupled with Plaintiffs and Alfa 4 being
the subject of CIR 112, falsely suggests that Plaintiffs and Alfa cooperated with a
Kremlin-orchestrated illegal campaign to influence the outcome of the 2016 U.S.
presidential election.
b. CIR 112 also states: “Significant favours continued to be done in both
directions, primarily political ones for PUTIN and business/legal ones for Alpha.” That
sentence defames Plaintiffs by accusing them of maintaining a relationship with Mr.
Putin that includes bribery and corruption.
c. CIR 112 also contains the following defamatory passage:
during the 1990s GOVORUN had been Head of Government

Relations at Alpha Group and in reality, the “driver” and “bag
carrier” used by FRIDMAN and AVEN to deliver large amounts of
illicit cash to the Russian president, at that time deputy Mayor of
St Petersburg. Given that and the continuing sensitivity of the
PUTIN-Alpha relationship, and need for plausible deniability,
much of the contact between them was now indirect and entrusted
to the relatively low profile GOVORUN.
4
In CIR 112, Alfa was misspelled as “Alpha” but the reference has been interpreted as meaning the Alfa Group of
entities, including Alfa Bank, with which Plaintiffs are affiliated.
5
The defamatory meaning of the first sentence of this passage is an accusation of
bribery—illicit cash paid by Plaintiffs Fridman and Aven to a government official, Vladimir
Putin—through an intermediary, Oleg Govorun. The defamatory meaning of the second sentence
of this passage is that it accuses Plaintiffs of continuing to use Mr. Govorun to have indirect
“contact” with Mr. Putin because of the alleged past cash bribes delivered through Mr. Govorun
and the need for “plausible deniability.” Ex. B, Plaintiffs’ Supplemental Responses to
Interrogatory No. 2.
The foregoing allegations in CIR 112 are false and defamatory, as alleged in Plaintiffs’
Amended Complaint (the “Complaint”) in this Action. Dkt. 17. Plaintiffs seek a judgment
against Defendants finding that statements about Plaintiffs in CIR 112 are false and defamatory
and that Defendants published them. Plaintiffs seek compensatory and/or punitive damages in
amounts to be proven at trial, together with interest and costs and fees.
9. Defendants deny any liability to Plaintiffs and have asserted several defenses,
including that the statements about Plaintiffs are not materially false; the publication of the
statements was privileged or otherwise protected by, inter alia, the First Amendment of the U.S.
Constitution, the neutral report privilege, and/or the fair report privilege (under New York Civil
Rights Law Section 74); and Plaintiffs should be treated as “public figures” (either general
purpose public or limited purpose), a category which subjects Plaintiffs to a burden to show that
the defamatory statements were published with “actual malice” (i.e., published with the
knowledge that the statements were false or with reckless disregard to whether they were true or
false).
10. In the years after Defendants published CIR 112 and the other election reports
that Mr. Steele prepared for Defendants, the reliability and accuracy of what Mr. Steele produced
6
has been the subject of: (a) a 2019 report by Michael Horowitz, the Inspector General for the
U.S. Department of Justice (the “Horowitz Report”); and (b) a 2020 court judgment rendered in
connection with a lawsuit filed by Plaintiffs against Mr. Steele’s company, Orbis, (the “U.K.
Judgment” or the “U.K. Proceeding”). Although CIR 112 was not itself central to the focus of
the Horowitz Report, the Horowitz Report was broadly critical of the work Mr. Steele did for
Defendants as unreliable. 5 CIR 112 was central to the U.K. Court Judgment against Mr. Steele.
In the U.K. Judgment, the English High Court rendered a judgment against Orbis in favor of
Plaintiffs, determining that the statements about Plaintiffs in CIR 112 are “inaccurate or
misleading as a matter of fact.” 6
Plaintiffs have represented that they do not seek disclosure of communications or
documents that are protected from disclosure by the attorney-client privilege, work product
doctrine, or other applicable privilege, nor do they seek to circumvent any privilege assertions,
however Plaintiffs do not waive the right to object to or challenge the propriety or validity of
claims that documents are privileged and the basis of such privilege claims. Although Orbis
produced to Plaintiffs some documents of Orbis and Mr. Steele in the U.K. Proceeding, no
documents relating to the creation or publication of CIR 112 were produced and Plaintiffs have a
good faith belief, bolstered by recent admitted failures of disclosure by Mr. Steele in a similar
5
See Ex. D, Officer of the Inspector General Michael Horowitz, U.S. Department of Justice, Review of Four FISA
Applications and Other Aspects of the FBI’s Crossfire Hurricane Investigation (Dec. 2019), available at
https://www.justice.gov/storage/120919-examination.pdf (“Horowitz Report”) at 384 (“In addition to the lack of
corroboration, we found that the FBI's interviews of Steele, the Primary Sub-source, and a second sub-source, and
other investigative activity, revealed potentially serious problems with Steele's description of information in his
election reports.”); 186 (“FBI conducted interviews . . . that raised significant questions about the reliability of the
Steele election reporting.”).
6
Ex. G, Judgment dated July 8, 2020, Aven and others v. Orbis Business Intelligence Ltd., [2020] EWHC 1812
(QB), available at https://www.bailii.org/ew/cases/EWHC/QB/2020/1812.html (“U.K. Judgment”) at ¶ 204.
7
matter involving Mr. Steele in the U.K., 7 that relevant documents exist and/or that Orbis and/or
Mr. Steele neglected to produce them. In addition, due to (i) Mr. Steele's recent challenge to the
U.S. Department of Justice seeking copies of certain of documents from the U.K. Proceeding that
would normally be available under applicable English law 8 and (ii) the restrictions on the use of
certain other documents produced in the U.K. Proceeding pursuant to rule 31.22 of the English
Civil Procedure Rules (“CPR”), Plaintiffs seek a separate order from the High Court permitting
disclosure of evidence for use in this U.S. proceeding. 9
11. Christopher Steele, co-founder and director of Orbis, 10 conducted the research
for and compiled the information in CIR 112, including the defamatory statements about
Plaintiffs at issue in this Action, and disclosed or provided CIR 112 (and the other reports that
have collectively become known as the “Dossier”) to multiple journalists and to other non-
parties. 11 Defendants have formally identified Mr. Steele as an individual likely to have
information relevant to this Action and Defendants’ claims and defenses, specifically
information regarding the “experience, work, process, and engagement by Defendants; [Mr.
Steele’s] communications with the FBI, Senator John McCain, the U.S. Department of Justice,
and other governmental agencies and officials; CIR 112, including recipients of CIR 112,
research related to matters in CIR 112, events related to topics in CIR 112, and delivery of CIR
7
In the proceedings captioned Aleksej Gubarev and another v (i) Orbis Business Intelligence Limited and (ii)
Christopher Steele, Claim No. HQ17D00413, in the High Court of Justice, Queen’s Bench Division, the trial of
which recently took place between 20-24 July 2020 (“Gubarev U.K. Proceeding”). See Ex. M, Defendants’ Closing
Submissions in the Gubarev U.K. Proceeding (which were made public during the trial) at 52-57.
8
In the matter of an application by the United States of America (the United States Department of Justice) made in
the U.K. Proceeding.
9
Pursuant to CPR 31.22, documents disclosed between parties in a U.K. legal proceeding may only be used “for the
purpose in which it is disclosed” unless certain exceptions apply, such as if the “the court gives permission” or “the
document has been read to or by the court, or referred to, at a hearing which has been held in public.”
10
Mr. Steele is a director and joint founder of Orbis. See https://orbisbi.com/about-orbis/.
11
See, e.g., Ex. A, Crime in Progress at 109-111 (describing Defendant Glenn Simpson’s and Mr. Steele’s briefings
to journalists); 127-128 (describing Mr. Steele’s briefing of David Kramer, and Defendant Simpson’s provision of a
copy of the entire so-called Dossier to Mr. Kramer).
8
112.” Ex. C (Defendants’ First Amended Rule 26(a)(1) Initial Disclosures (“Defendants’ Initial
Disclosures”), Section 1).
12. Christopher Burrows co-founded Orbis with Mr. Steele, 12 and Mr. Burrows
played a role in shaping the content of the Dossier, is knowledgeable about the source(s) of the
allegations in the Dossier, and participated in briefings about the Dossier and dissemination of its
contents. 13 Additionally, Defendants have identified Mr. Burrows as an individual likely to have
information relevant to this Action and Defendants’ claims and defenses, specifically knowledge
of “relevant conduct of Orbis and Christopher Steele; Christopher Steele, including his
experience, work, process, and engagement by Defendants.” Ex. C, Defendants’ Initial
Disclosures, Section 1.
13. Orbis is the U.K.-based intelligence gathering firm founded by Mr. Steele and
Mr. Burrows which was retained by Defendants in 2016 and which produced CIR 112, including
the statements about Plaintiffs at issue in this Action. Defendants acknowledge engaging Orbis
to “look into then-candidate Trump’s activities in Russia, in support of Defendants’ ongoing
research activities” and that Mr. Steele and Mr. Burrows were some of the people at Orbis with
whom “Defendants mainly communicated.” Ex. F, Defendants’ Answer to Interrogatory No. 12.
14. Edward Baumgartner is the co-founder of the U.K.-based research and
intelligence firm Edward Austin Limited. 14 Defendants have formally identified Mr.
12
Mr. Burrows is a director and joint founder of Orbis. See https://orbisbi.com/about-orbis/.
13
See, e.g., Ex. A, Crime in Progress at 77 (discussing Mr. Burrows’ role in 2016 selecting information that was
included in the Dossier), 82-84 (stating that Mr. Burrows and Mr. Steele have refused to reveal the identity of
source(s) for the information in the Dossier, and discussing the briefing of an FBI agent in 2016 by Mr. Burrows and
Mr. Steele of their “findings and sources”).
14
Mr. Baumgartner is a founder and managing director of Edward Austin Limited. See https://www.edward-
austin.com/about/team/.
9
Baumgartner as an individual likely to have information relevant to this Action and Defendants’
claims and defenses, specifically:
Relevant conduct of Plaintiffs; Plaintiffs’ roles in the business

world; Plaintiffs’ ties, communications, meetings, and relations
with the Kremlin, Vladimir Putin, and those representing them or
acting on their behalf; Alfa, including entities affiliated with Alfa;
Alfa’s ties to the Kremlin and Vladimir Putin; Alfa’s investments
in U.S. companies; research related to matters in CIR 112.
Ex. C, Defendants’ Initial Disclosures, Section 1.
15. Sir Andrew Wood is a former British diplomat who is an Associate Fellow in the
Russia and Eurasia Programme at Chatham House in the U.K. 15 He has been identified as a
mentor to Mr. Steele with whom Mr. Steele discussed or transmitted the research at issue in this
Action in 2016 at around the time that CIR 112 was completed and sent to Defendant Fusion.
He also communicated with David Kramer and Senator John McCain about Mr. Steele’s research
in the reports and arranged a meeting between Mr. Kramer and Mr. Steele regarding the
reports. 16 Defendants have formally identified Sir Andrew Wood as an individual likely to have
information relevant to this Action and Defendants’ claims and defenses, including the “receipt
and delivery of CIR 112.” 17
16. Plaintiffs seek relevant evidence for use at trial on the merits of the case.
Plaintiffs do not seek disclosure of communications or documents that are protected from
disclosure by the attorney client privilege, work product doctrine, or other applicable privilege,
nor do they seek to circumvent any privilege assertions, however Plaintiffs do not waive the right
15
See https://www.chathamhouse.org/expert/sir-andrew-wood.
16
Ex. A, Crime in Progress at 107 (Mr. Steele “reached out to a mentor, Sir Andrew Wood, Britain’s former
ambassador to Moscow, to seek his advice and share the intelligence he had gathered.”); 126-27 (meeting between
Sir Andrew Wood and David Kramer and Senator John McCain in Halifax, Nova Scotia, which involved
discussions of Mr. Steele’s research and reports; Sir Andrew Wood arranged a meeting in London between Mr.
Steele and Mr. Kramer).
17
Ex. C, Defendants’ Initial Disclosures, Section 1.
10
to object to or challenge the propriety or validity of claims that documents are privileged and the
basis of such privilege claims.
17. Plaintiffs respectfully request that the Court issue the attached Letter of Request
for International Judicial Assistance which requests the production of relevant evidence and
testimony from the aforementioned individuals and Orbis. 18 Plaintiffs’ proposed requests to
each individual and to Orbis, and the relevance to this Action of the evidence requested from
each, is set forth below.
III. PLAINTIFFS’ REQUESTS FOR ORAL EXAMINATION AND THE

PRODUCTION OF DOCUMENTARY EVIDENCE
A. Christopher Steele
18. Oral Examination of Mr. Steele. It is expected that Mr. Steele will be able to
provide crucial and relevant testimony on a number of topics. Those topics, and the relevance of
each, are set forth below:
No. 1: In general terms, Mr. Steele’s educational background, employment history,

professional qualifications and personal preparation for the examination (including contacts with
the parties, their lawyers, insurers, or representatives), excluding any privileged communications
or confidential details regarding any government service.
Relevance: Mr. Steele’s general educational and employment background are relevant to
his credibility and reliability as a witness and as an expert on matters relating to Russia. Mr.
Steele holds himself out as an expert related to Russia and compiled CIR 112 as part of an
engagement that was based on his claimed Russia expertise. Additionally, Defendants asked Mr.
18
The term “documents” shall have the same broad meaning and scope as given to these terms in or pursuant to the
Federal Rules of Civil Procedure and applicable law, and shall include hard copy documents and files as well
electronic or computerized data, e-mails, text messages, etc. The term “communications” shall mean the transmittal
of data or information by any means, including meetings, conversations, discussions, documents, correspondence,
messages, text messages, e-mails, notes, WhatsApp messages, Slack messages, Skype messages, or other means of
transmittal.
11
Steele and Orbis to prepare CIR 112, 19 and Defendants have acknowledged that they “obtained
CIR 112 from Mr. Steele”; have stated that Mr. Steele is “a trusted, experienced, and well-
respected source” as a basis for trusting the veracity of the statements in CIR 112; and have
indicated they had conversations with Mr. Steele regarding “the content of CIR 112, the quality
of the sourcing, the competence of Mr. Steele’s team, the potential for misinformation, and
efforts to verify the information in CIR 112”—all of which is relevant to the issues in the Action.
See Ex. F, Defendants’ Answer to Interrogatory No. 5. Plaintiffs should be entitled to ask Mr.
Steele general background questions to probe the basis for his alleged expertise and to provide
context to his qualifications and credibility as a witness.
No. 2: Retention of Mr. Steele and/or Orbis in 2016 by Fusion relating to CIR 112 and
the scope and purpose of the retention.
Relevance: In order to prevail on their claim for defamation, Plaintiffs must demonstrate
that the defamatory statements are false and that Defendants acted with fault in publishing the
defamatory statements. See Farah v. Esquire Mag., 736 F.3d 528, 533-34 (D.C. Cir. 2013).
Plaintiffs contend the relevant fault standard is negligence; the Defendants contend the relevant
fault standard is actual malice. 20 The scope and purpose of the retention of Orbis and Mr. Steele
19
As indicated in the recent Judgment in the proceeding brought by Plaintiffs against Orbis under the U.K. Data
Protection Act, Mr. Steele and Orbis communicated with and received instructions in or about July 2016 from
Defendant Fusion to conduct research on Alfa and Plaintiffs and to prepare CIR 112 in connection with concerns
about potential Russian interference in the U.S. Presidential election process and suspected communications
between the servers of Alfa Bank and Trump Tower. Ex. G, U.K. Judgment ¶¶ 74, 87.
20
One of Defendants’ affirmative defenses is that Plaintiffs are limited purpose public figures and that they must
show that Defendants published the statements with actual malice, a standard that is met if it can be shown that the
statement was made with a “reckless disregard for whether or not the statement was false.” See, e.g. St. Amant v.
Thompson, 390 U.S. 727, 728 (1968). Plaintiffs dispute that they are public figures and that the actual malice
standard is applicable.
To determine whether Plaintiffs are limited purpose public figures, the Court must determine what controversy
“gave rise” to the defamatory statements. See Gertz v. Robert Welch, Inc., 418 U.S. 323, 352 (1974) (in determining
public figure status, courts look “to the nature and extent of an individual’s participation in the particular
controversy giving rise to the defamation”). The parties disagree as to whether the relevant controversy is Russian
interference with the 2016 election (as reflected in the title of CIR 112 and the subject of Mr. Steele’s report), or the
12
by Defendant Fusion which led to the preparation of CIR 112 by Orbis and Mr. Steele is relevant
to whether the research was intended to convey truthful information, the level of care that was
taken to ensure the information was truthful, and the motives for publication and dissemination
of CIR 112.
Defendants acknowledge engaging Orbis, which Steele co-founded, to “look into then-
candidate Trump’s activities in Russia, in support of Defendants’ ongoing research activities,”
and that Steele was one of the people at Orbis with whom “Defendants mainly communicated.”
Ex. F, Defendants’ Answer to Interrogatory No. 12. Defendants acknowledge that they “had a
copy of an engagement letter with Orbis and/or Christopher Steele” but no longer have a copy
and “do not recall whether [it] was returned to [Orbis/Steele] or destroyed.” Ex. F, Defendants’
Answer to Interrogatory No. 23. And Orbis and Mr. Steele prepared several research reports,
including CIR 112 (dated September 14, 2016) which contains the defamatory statements, and
transmitted CIR 112 to Defendants and others.
No. 3: Communications and meetings in 2016 and 2017 between Mr. Steele and
Defendants Glenn Simpson or Fusion or any Fusion sub-contractors regarding Plaintiffs, Alfa,
CIR 112, or the statements about Plaintiffs in CIR 112.
Relevance: As set forth in No. 2, supra, relevant issues in this Action include whether
the defamatory statements about Plaintiffs in CIR 112 are false and whether Defendants acted
with fault (either negligence or actual malice) in publishing the defamatory statements.
Communications between Mr. Steele and Fusion regarding Plaintiffs, Alfa, CIR 112, and the
broader subject of Russian oligarchs and their business interests and relationship with the Kremlin. Accordingly, the
reasons why the defamatory statements were created and published are relevant issues, and thus the scope and
purpose of Orbis’s retention by Fusion for the preparation of CIR 112 are relevant.
In addition, to the extent that Plaintiffs are found to be limited purpose public figures, the Defendants’ motive for
publishing the defamatory statements is relevant to whether the defendant acted with actual malice. See Harte-
Hanks Commc’s, Inc. v. Connaughton, 491 U.S. 657, 664-65, 667-68, 689 n. 36 (1989); accord Tavoulareas v. Piro,
817 F.2d 762, 796 (D.C. Cir. 1987). Communications between Defendants and Orbis and Mr. Steele regarding the
scope of the retention are in turn relevant to the motives for compiling and publishing CIR 112.
13
statements about Plaintiffs in CIR 112 are relevant to whether the defamatory statements were
false, and whether the Defendants acted negligently or recklessly in publishing the statements. It
has been acknowledged that Mr. Steele and Defendants communicated about the research and
sourcing for the Dossier (which included CIR 112). 21
No. 4: Communications and meetings in 2016 and 2017 between Mr. Steele and Jonathan
Winer regarding Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in CIR 112.
Relevance: Mr. Winer was an official at the U.S. State Department during the relevant
time period, to whom Defendants disclosed a copy of CIR 112. Ex. F, Defendants’ Answer to
Interrogatory No. 9. Mr. Steele discussed the research reports with Mr. Winer and Mr. Winer
served as a conduit between Mr. Steele and the State Department. 22 Mr. Steele’s
communications and meetings with Mr. Winer in 2016 about the Dossier have been described by
Defendant Simpson. 23 Communications and meetings with Mr. Winer, or other government
21
Defendants acknowledge that Mr. Steele was one of the people at Orbis with whom “Defendants mainly
communicated.” Ex. F, Defendants’ Answer to Interrogatory No. 12. See also Ex. A, Crime in Progress at 5-6
(referencing 2016 communications between Defendants and Mr. Steele about the Dossier, which included CIR 112);
77 (after Mr. Steele sent Defendants the first report in June 2016, Defendant Simpson spoke with Mr. Steele about
sourcing via an encrypted phone line); 108-12 (discussions in 2016 about the research in the Dossier with reporters
and media members involving Mr. Steele and Defendant Simpson); 149-50 (communications with Defendants in
2017 after the Dossier was published); 230-31 (communications about the Dossier later in 2017 in connection with
investigations by U.S. authorities).
See also Ex. G, U.K. Judgment at ¶¶ 74, 87 (Mr. Steele and Orbis communicated with and received instructions
from Fusion to conduct research on Alfa and Plaintiffs and to prepare CIR 112 in connection with concerns about
potential Russian interference in the U.S. Presidential election process and suspected communications between the
servers of Alfa Bank and Trump Tower).
22
See Ex. H, Jonathan M. Winer, Devin Nunes is investigating me. Here’s the truth, Wash. Post (Feb. 8, 2018),
https://www.washingtonpost.com/opinions/devin-nunes-is-investigating-me-heres-the-truth/2018/02/08/cc621170-
0cf4-11e8-8b0d-891602206fb7_story.html (Mr. Winer wrote that he “alert[ed]” the U.S. State Department of the
allegations in Mr. Steele’s memoranda.).
23
See Ex. A, Crime in Progress at 107 (reporting that on September 14, 2016, when Mr. Steele sent his seventh
research report to Fusion (i.e., CIR 112), Mr. Steele “messaged his contact at the State Department, Jonathan Winer,
to let him know he had developed disturbing information about Trump’s ties to Russia” and “asked to meet [Winer]
in person the next time [Steele] was in Washington”); 112-13 (regarding a September 2016 meeting between Mr.
Steele and Mr. Winer in which Mr. Steele disclosed to Mr. Winer the contents of the research in the Dossier, which
led Mr. Winer to contact Peter Fritsch, co-founder of Defendant Fusion, who allowed Mr. Winer to review the
reports and take notes for further dissemination of the information).
See also Ex. D, Horowitz Report at 117 (Mr. Steele met with Jonathan Winer on 11 October 2016, and notes of the
meeting reflect that Mr. Steele addressed a wide array of topics, including the role of Alfa Bank as a conduit for
14
officials, and what was said about the credibility of the allegations about Plaintiffs in CIR 112
and Mr. Steele’s reports and research generally, are relevant to the falsity of the statements and
whether Defendants acted negligently or recklessly in publishing CIR 112—which are issues
relevant in this Action. See No. 3 above, supra.
No. 5: Communications and meetings in 2016 and 2017 between Mr. Steele and reporters
or news or media organizations regarding Plaintiffs, Alfa, CIR 112, or the statements about
Plaintiffs in CIR 112.
Relevance: In order to prevail on their claim for defamation, Plaintiffs must show that
Defendants published the defamatory statements. Farah, 736 F.3d at 533-34. In the Complaint,
Plaintiffs have alleged that the Defendants “arranged for Steele to brief selected members of the
print and online media about the information he was compiling.” Am. Compl. ¶ 6, Dkt. 17.
Defendant Simpson has reported that he and Mr. Steele had meetings and communications in
2016 with reporters and media companies regarding the election-related research in the Dossier,
and Mr. Steele has similarly reported having meetings in 2016 with the media, at the direction of
Defendant Fusion, to discuss the election-related research findings. 24 Defendants acknowledge
that they provided copies of CIR 112 to the New York Times, Mother Jones, and other third
secret communications between the Trump campaign and the Kremlin); 119 (Two days after the meeting on 11
October, Kathleen Kavalec of the U.S. State Department emailed a FBI Section Chief a document received from Mr.
Winer which discussed allegations about a linkage between Alfa Bank and the Trump Campaign, and Ms. Kavalec
said that the information in the document related to Mr. Steele’s investigation.).
24
See Ex. A, Crime in Progress at 108-112 (regarding Mr. Steele’s meetings with reporters from various
publications to disclose the contents of the reports that became known as the Dossier); 118-19 (regarding a three
way Skype call on October 31, 2016 regarding the research and information in the Dossier with David Corn of
Mother Jones, Mr. Steele, and Defendant Simpson); 141-43 (referring to a December 31, 2016 text message from
Ken Bensinger of BuzzFeed to Mr. Steele on the day that Mr. Bensinger obtained a copy of the Dossier from David
Kramer, and wanting to meet Mr. Steele in London on January 3, a few days before Mr. Bensinger published the
Dossier as part of a BuzzFeed article).
See also Ex. D, Horowitz Report at 104-05 (in late September 2016, Mr. Steele, as tasked by Fusion, briefed
journalists from The New York Times, The Washington Post, Yahoo News, The New Yorker and CNN regarding his
research and reports on election interference by Russia); 117 (Mr. Steele returned in mid-October 2016 to give
further briefings to the New York Times, The Washington Post and Yahoo News).
15
parties in 2016. Ex. F, Defendants’ Answer to Interrogatory No. 9. In addition, according to
Defendant Simpson, Mr. Steele communicated via text message with Mr. Bensinger of BuzzFeed
on December 31, 2016 and met with Mr. Bensinger on January 3, 2016 regarding the reports—
days before Mr. Bensinger and BuzzFeed published all the reports on the internet. 25 Mr. Steele’s
and Defendants’ meetings and communications with reporters, or news or media organizations
are directly relevant to Defendants’ “publication” of CIR 112—a relevant issue in this
defamation Action. Further, what was conveyed to the media and other third parties is relevant
to the falsity of the statements in CIR 112 and whether publication was done negligently or
recklessly—relevant issues in this Action.
Additionally, in their motion to dismiss, Defendants claimed that any briefing to
journalists would “not have included any mention of Plaintiffs or the contents of CIR 112.”
Defendants’ Motion to Dismiss the Amended Complaint for Failure to State a Claim (“Mot.
Dismiss”) at 33, Dkt. 20. Plaintiffs should be entitled to test this assertion by questioning Mr.
Steele as to whether he mentioned or discussed Plaintiffs, Alfa, or CIR 112 during his meetings
with reporters, or news or media organizations.
No. 6: Communications and meetings in 2016 and 2017 between Mr. Steele and David
Kramer regarding Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in CIR 112.
Relevance: Defendants have acknowledged providing a copy of CIR 112 in 2016 to Mr.
Kramer, a former U.S. State Department official and adviser to U.S. Senator John McCain (Ex.
F, Defendants’ Answer to Interrogatory No. 9), and that Mr. Steele had communications and
meetings with Mr. Kramer in 2016 regarding his election-related research and reports,
dissemination of the reports (including CIR 112), and the factual support for and “credibility of
25
Ex. A, Crime in Progress at 143-44.
16
the reporting.” 26 These facts are relevant to the issues of publication, falsity of the statements
about Plaintiffs, and Defendants’ negligence or recklessness (based on what was said in such
meetings and communications).
Defendants have claimed that they did not provide CIR 112 to Mr. Bensinger or
BuzzFeed (Mot. Dismiss at 15, Dkt. 20), however it has been reported and acknowledged that
Mr. Steele asked Defendant Simpson to provide a copy of the Dossier (which included CIR 112)
to Mr. Kramer in 2016 after meeting with Mr. Kramer in London, and that Defendants published
the defamatory statements to Mr. Kramer by providing him a copy, as alleged in the Complaint.
Am. Compl. ¶ 7, Dkt. 17; Ex. A, Crime in Progress at 127-28, and Ex. F, Defendants’ Answer to
Interrogatory No. 9. In another litigation emanating from the publication of the Dossier, Mr.
Kramer has been found to have provided “all seventeen [Steele] memos” (including CIR 112) to
BuzzFeed (which then published the 17 memos on the internet). See Gubarev v. BuzzFeed, Inc.,
340 F. Supp. 3d 1304, 1311 (S.D. Fla. 2018). Accordingly, Mr. Steele’s communications with
Mr. Kramer (on behalf of Defendants) are relevant to Defendants’ role in publishing CIR 112 for
wide dissemination.
No. 7: The drafting and compilation in 2016 of CIR 112 and its promotion.
26
See Ex. A, Crime in Progress at 127 (Mr. Steele met with Mr. Kramer in November 2016 and showed him the
Dossier (including CIR 112) and they discussed the reports, the research, and the factual support); 128 (Mr. Steele
asked Defendant Simpson to provide a copy of the reports to Mr. Kramer, which he did); 142 (referencing
December 29, 2016 text messages between Mr. Kramer and Mr. Steele regarding communications with Ken
Bensinger of BuzzFeed, which ultimately published the reports with an article on January 10, 2017); 143 (Mr.
Kramer allowed Mr. Bensinger to copy the reports, which Mr. Bensinger then published along with the January 10
article). See also Ex. G, U.K. Judgment at ¶¶ 51-52 (Mr. Steele disclosed CIR 112 and other memoranda to Mr.
Kramer in 2016, and “at some point between late November 2016 and 10 January 2017, Mr. Kramer gave Buzzfeed
access to the Steele Dossier, thereby causing or contributing to the publication of the Buzzfeed Article”), 53
(communications between Mr. Steele and Mr. Kramer in December 2016 regarding disclosure of CIR 112 to a
senior US national security official); 118 (meeting between Mr. Steele and Mr. Kramer in November 2016 and
subsequent request for copies of the reports including CIR 112).
17
Relevance: Defendants acknowledge engaging Orbis, which Mr. Steele co-founded, to
“look into then-candidate Trump’s activities in Russia, in support of Defendants’ ongoing
research activities,” that Orbis and Mr. Steele prepared CIR 112 and Defendants “obtained CIR
112 from Mr. Steele” and Orbis, and that Defendants had conversations with Mr. Steele
regarding “the content of CIR 112, the quality of the sourcing, the competence of Mr. Steele’s
team, the potential for misinformation, and efforts to verify the information in CIR 112” (Ex. F,
Defendants’ Answers to Interrogatory Nos. 5, 12) 27—all of which is relevant to the issues in the
Action (including the falsity of the statements about Plaintiffs, and the negligence or recklessness
in publication of such statements). In addition, Department of Justice Inspector General Michael
Horowitz was broadly critical of the work Steele did for Defendants as unreliable 28 and the
recent English High Court judgment against Orbis in favor of Plaintiffs (under the U.K. Data
Protection Act) determined that the statements about Plaintiffs in CIR 112 are “inaccurate or
misleading as a matter of fact.” 29 Accordingly, Plaintiffs should be able to question Mr. Steele
27
See also Ex. G, U.K. Judgment at ¶¶ 74-75, 87 (regarding engagement of Orbis and Mr. Steele to prepare CIR 112
and the preparation thereof).
28
See Ex. D, Horowitz Report at 384 (“In addition to the lack of corroboration, we found that the FBI's interviews of
Steele, the Primary Sub-source, and a second sub-source, and other investigative activity, revealed potentially
serious problems with Steele's description of information in his election reports.”); 187 (a source indicated that Mr.
Steele “misstated or exaggerated …statements in multiple sections of the reporting”); 188 (a source reported that
“the tenor of Steele's reports was far more ‘conclusive’ than was justified”); 186 (“FBI conducted interviews . . .
that raised significant questions about the reliability of the Steele election reporting.”); 133 (“neither Steele nor the
Primary Sub-source had direct access to the information being reported”).
The U.S. Senate Judiciary Committee was also critical of Mr. Steele’s research and reporting. See Ex. E, Senate
Judiciary Committee Release, July 17, 2020 available at
https://www.judiciary.senate.gov/press/rep/releases/judiciary-committee-releases-declassified-documents-that-
substantially-undercut-steele-dossier-page-fisa-warrants (evidence shows “how unsubstantiated and unreliable the
Steele dossier was;” the “primary ‘source’ of Steele’s election reporting was not some well-connected current or
former Russian … [and] information that Steele’s primary source provided him was second and third-hand
information and rumor at best”).
29
Ex. G, U.K. Judgment at ¶ 204.
18
about these credibility and accuracy problems that bedeviled his project for Defendants (which
including the preparation of CIR 112).
In support of their motion to dismiss, Defendants claimed that much of the complained-of
statements in CIR 112 are not defamatory because they do not suggest a corrupt relationship
between Plaintiffs and Russian President Vladimir Putin. See, e.g. Mot. Dismiss at 19-20, Dkt.
20. Although Plaintiffs contend that Defendants’ interpretation is nonsensical and the
defamatory import of being accused of a close relationship with Mr. Putin in which “favours”
were done in both directions is inarguable, Defendants have placed the meaning and
interpretation of these words at issue. Accordingly, Plaintiffs should be entitled to question Mr.
Steele as to the drafting and compilation of CIR 112 and what was intended to be conveyed by
the description of their relationship with Mr. Putin.
Plaintiffs have alleged that CIR 112’s heading defames them by linking them to Russian
interference in the 2016 presidential election. Am. Compl. ¶ 19, Dkt. 17. Defendants have
claimed that CIR 112 did not link Plaintiffs to the election interference controversy because the
contents of CIR 112 (as opposed to its heading) do not concern the 2016 presidential election or
Mr. Trump. Mot. Dismiss at 17-18, Dkt. 20. Plaintiffs should be entitled to question Mr. Steele
regarding the structure of CIR 112, including why it was given the heading it bears, which is
relevant to the defamatory import of CIR 112.
No. 8: Delivery, transmission, or disclosure of CIR 112 in 2016 and 2017 to other
persons or entities, including Defendants, Mr. Kramer, Mr. Winer, reporters and members of the
media.
Relevance: Defendants acknowledge that Orbis and Mr. Steele delivered or transmitted
CIR 112 to Defendants and that Defendants disclosed or transmitted copies of CIR 112 to several
third parties, including Mr. Kramer, Mr. Winer, reporters and members of the media. Ex. F,
19
Defendants’ Answers to Interrogatory Nos. 5, 9. Mr. Steele and Orbis also disclosed or
transmitted copies of CIR 112 to others, such as the FBI, Strobe Talbott, a U.K. government
official, and David Kramer. 30 This topic concerns the publication of CIR 112, which, as
discussed, is a relevant issue in the Action.
Defendants claim that even if they are liable for publishing CIR 112, their liability is
limited because all they did was tell “a select few journalists about the contents of other reports”
in the collection of memoranda and did not give journalists copies of the memoranda. Mot.
Dismiss at 36, Dkt. 20. Mr. Steele was present during the media briefings regarding his reports,
disclosed information regarding his reports to members of the media at Defendants’ direction,
and assisted Defendants in disseminating the reports to a wide audience by meeting with
government officials, in which Alfa was discussed. 31 In his December 2019 report, U.S.
Department of Justice Inspector General Horowitz reported that in October 2016, Mr. Steele
talked about Alfa Bank during a meeting with the U.S. State Department. Specifically, Steele
mentioned an allegation that Alfa was a “conduit for secret communications between [Paul]
Manafort and the Kremlin,” and another “about a linkage between Alfa Bank and the Trump
Campaign.” 32 And while those allegations were not included in CIR 112, Mr. Steele evidently
disclosed CIR 112 to a reporter from Mother Jones.” 33 Plaintiffs should be entitled to
30
See Ex. G, U.K. Judgment at ¶ 51 (summarizing the disclosures by Mr. Steele and Orbis).
31
See, e.g., Ex. A, Crime in Progress 108-11 (describing Defendant Simpson’s and Mr. Steele’s briefings to
journalists); 112 (Mr. Steele met with U.S. State Department Official Jonathan Winer regarding the Dossier); 128
(Mr. Steele told David Kramer that he had shared his research information with the FBI and facilitated Defendant
Simpson providing a copy of CIR 112 to Mr. Kramer so that it could be further disseminated to a government
official). See also Ex. G, U.K. Judgment at ¶¶ 59, 113(5) (“Mr. Steele admits briefing journalists about Orbis’ work,
and the documentary evidence and cross-examination make it clear that, in and after late September 2016 he was
heavily and enthusiastically involved in doing so.”).
32
See Ex. D, Horowitz Report 117, 119.
33
See Ex. D, Horowitz Report 175.
20
information relating to Defendants’ role in disclosing and publishing CIR 112 on which Mr.
Steele has knowledge.
No. 9: The steps taken by Mr. Steele, Orbis, or Defendants to corroborate, verify or
investigate the information and statements about Plaintiffs in CIR 112.
Relevance: In order to prevail on their claim for defamation, Plaintiffs must prove that
the defamatory statements are false and that Defendants acted with fault (either negligence or
actual malice) in publishing the defamatory statements. See Farah, 736 F.3d at 533-34.
Defendants have indicated that they “do not know the identity of Steele’s sources for CIR 112”
but trusted Mr. Steele and had conversations with him about “the efforts to verify the information
in CIR 112.” Ex. F, Defendants’ Answers to Interrogatory Nos. 4, 5. In addition, the U.S.
Department of Justice has reported on the problems with the sourcing and accuracy of Mr.
Steele’s reports. See page 7, note 5, supra.
The steps taken, if any, to corroborate, verify, or investigate the statements about
Plaintiffs in CIR 112 are directly relevant to this Action, and efforts (or lack thereof) by
Defendants and their subcontractors, such as Mr. Steele who compiled CIR 112, are relevant to
Defendants’ negligence or recklessness in publishing CIR 112. If Defendants, Orbis, or Mr.
Steele (a) attempted to, but did not succeed in, corroborating the statements in CIR 112, (b)
failed to investigate or corroborate statements from sources, or (c) found any information that
contradicted the statements in CIR 112—it supports the inference that they were negligent or
reckless in publishing false statements about Plaintiffs, which are relevant issues in the Action.
No. 10: The destruction, return, or non-retention of the following documents: (a) CIR
112, including work product, memoranda, source information, drafts or analysis relating to CIR
112; (b) communications between Mr. Steele and Defendants Simpson or Fusion in respect to
CIR 112; and (c) engagement agreements between Mr. Steele and/or Orbis on one hand and
Fusion on the other which govern the creation or promotion of CIR 112.
21
Relevance: Defendants have not produced any documents relating to CIR 112, and
Defendants, Orbis, and Mr. Steele have all previously indicated that they routinely destroy or
return documents and did not retain documents relating to CIR 112 that are relevant to this
Action. For example, Defendants acknowledge that they had a copy of an engagement letter
with Orbis and/or Mr. Steele, but no longer have a copy and do not recall whether it was returned
to Orbis/Mr. Steele or destroyed. Ex. F, Defendants Answer to Interrogatory 23. Defendants
also acknowledge that they previously had an encrypted copy of CIR 112 that was received from
Orbis, as well as documents relating to the statements about Plaintiffs in CIR 112 (responsive to
Plaintiffs’ Document Request 26), including a memorandum, but that they no longer have copies
of such documents and “do not recall whether document[s] [were] returned to [Orbis] or
destroyed.” Id. In the proceeding brought by Plaintiffs under the U.K. Data Protection Act, Mr.
Steele admitted that he destroyed relevant documents regarding his research for the reports
(which include CIR 112). 34 Plaintiffs should be entitled to probe this assertion to determine
when documents were destroyed, whether it was at the direction of Defendants, whether it was
done when litigation should have been anticipated, and whether any destroyed documents can be
recovered. If Defendants destroyed (or instructed others to destroy) relevant documents when
there was an anticipation of litigation, then Defendants could be subject to sanctions in this
Action. If Defendants returned relevant documents to Mr. Steele or to Orbis, Plaintiffs will want
to obtain such documents from Mr. Steele or Orbis. Plaintiffs should also be entitled to question
34
Ex. G, U.K. Judgment at ¶¶ 81 (Other than notes of a July 2016 meeting with the FBI, Mr Steele “kept few
records” regarding his research and “most of these he did keep have been lost or destroyed.”), 175 (CIR 112 “was
based on intelligence provided by a single source and a single sub-source” and “Mr Steele had a 2-hour meeting
with the source, and wrote up the memorandum shortly after, destroying the manuscript notes.”)
22
Mr. Steele as to why certain documents were retained (such as certain meeting notes) but not
other documents.
No. 11: Communications and meetings in 2016 and 2017 between Mr. Steele and Igor
Danchenko regarding Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in CIR 112.
Relevance: It was recently reported in the media that Mr. Steele’s primary source for his
election-related research and reports was Igor Danchenko, a U.S.-based researcher hired by
Orbis (not a well-connected official in Russia, as many previously believed). 35 Mr. Steele’s
meetings and communications with Mr. Danchenko regarding the subject matter of Mr. Steele’s
“Dossier” of memos (which included CIR 112) are relevant to the reliability of the research,
Defendants’ knowledge that Mr. Danchenko was a primary source, the falsity of the statements
in CIR 112, and whether Defendants’ publication was done negligently or recklessly—relevant
issues in this Action.
19. Documentary Evidence from Mr. Steele. It is expected that Mr. Steele will be
able to provide documentary evidence relevant and material to a number of issues in this Action.
The documents requested from Mr. Steele, and their relevance, are set forth below:
No. 1: Documents setting out the terms of Orbis’s and/or Mr. Steele’s engagement with
or retention by Fusion in connection with the compilation or preparation of CIR 112 and its
promotion.
No. 2: Documents setting out the scope and purpose of the work that Mr. Steele and
Orbis were to perform in connection with the compilation or preparation of CIR 112 and its
promotion.
Relevance: For the same reasons that testimony from Mr. Steele on the issues of Orbis’s
and Mr. Steele’s engagement by Fusion and the scope and purposes of the work to be performed
35
See Ex. N, Adam Goldman and Charlie Savage, The F.B.I. Pledged to Keep a Source Anonymous. Trump Allies
Aided His Unmasking, N.Y. Times (July 25, 2020), https://www.nytimes.com/2020/07/25/us/politics/igor-
danchenko-steele-dossier.html? Mr. Danchenko’s lawyer has indicated that he did not seek to have his identity
withheld from these media reports because his “name has already been exposed.” Id.
23
are relevant in this Action, as set forth in Paragraph 18, No. 2, supra, documents relating to these
issues are relevant and should be produced. Mr. Steele was involved in communications about
these issues, and Defendants have stated that documents relating to the engagement of Mr. Steele
or his firm Orbis once existed, but that Defendants destroyed such documents or returned them to
Mr. Steele or Orbis.
No. 3: Communications between Mr. Steele and Defendants Glenn Simpson or Fusion
(including documents referencing or referenced in such communications) regarding Plaintiffs,
Alfa, CIR 112, or the statements about Plaintiffs in CIR 112, within the period 01 April 2016 to
03 October 2017.
Relevance: As set forth in Paragraph 18, No. 3, supra, Mr. Steele and Defendants had
communications regarding the research and sourcing for the Dossier (which included the
defamatory statements about Plaintiffs in CIR 112). Documents, including communications,
between Orbis or Mr. Steele and Defendants regarding Plaintiffs, Alfa, and CIR 112 are relevant
to whether the defamatory statements are false, and whether the Defendants acted negligently or
recklessly in publishing the statements. The date range of this request is from the month (April)
that Fusion was retained in 2016 for the election-related research until the date Plaintiffs filed
their complaint in this Action.
No. 4: Communications between Mr. Steele and Jonathan Winer (including documents
referencing or referenced in such communications) regarding Plaintiffs, Alfa, CIR 112, or the
statements about Plaintiffs in CIR 112, within the period 01 September 2016 to 10 January 2017.
No. 5: Communications within the period 01 September 2016 to 10 January 2017

(including documents referencing or referenced in such communications) between Mr. Steele
and Mr. Winer relating to meetings regarding Plaintiffs, Alfa, CIR 112, or the statements about
Plaintiffs in CIR 112, including the meeting between Mr. Steele and U.S. Department of State
officials and Mr. Winer on or about 11 October 2016.
Relevance: As set forth in Paragraph 18, No. 4, supra, relating to oral examination on
this subject, Defendants disclosed CIR 112 to Mr. Winer, a U.S. State Department official, and
Mr. Steele had communications with Mr. Winer about his election-related reports. Documents
24
relating to these communications are relevant to issues in the Action, such as the publication of
the defamatory statements and whether Defendants acted negligently or recklessly in publishing
CIR 112. The date range of this request is from the month (September) in 2016 that CIR 112
was completed and Mr. Steele communicated and met with Mr. Winer regarding the reports until
the date that BuzzFeed published the Dossier on the internet (January 10, 2017).

and the New York Times, the New Yorker, the Washington Post, Yahoo! News, CNN, Mother
Jones and/or BuzzFeed, relating to meetings regarding Plaintiffs, Alfa, CIR 112, or the
statements about Plaintiffs in CIR 112, including the meeting between Mr. Steele and Michael
Isikoff and Jane Mayer at the Tabard Inn on or about 22 September 2016.

and the New York Times, the New Yorker, the Washington Post, Yahoo! News, CNN, Mother
Jones, and/or BuzzFeed regarding Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in
CIR 112.
No. 8: Communications (including documents referencing or referenced in such

communications) between Mr. Steele and David Corn of Mother Jones via Skype on 31 October
2016 regarding Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in CIR 112.
Relevance: As set forth in Paragraph 18, No. 5, supra, Mr. Steele and Defendant
Simpson met and had communications with media organizations and reporters (including those
referenced in the above requests) in 2016 to discuss the content of the memos prepared at the
direction of Defendants, and provided copies of CIR 112 to certain media organizations.
Documents relating to these communications are material to relevant issues in this Action,
including Defendants’ publication of the defamatory statements, the falsity of the statements, and
whether publication was done negligently or recklessly. The date range of these requests is from
the month (September) in 2016 that CIR 112 was completed and Mr. Steele first met with
reporters about the research and reports until the date that BuzzFeed published the Dossier on the
internet (January 10, 2017).

25

and David Kramer regarding Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in CIR
112, including text messages or other types of messages between Mr. Steele and Mr. Kramer on
or about 29 December 2016.
Relevance: See Paragraph 18, No. 6, supra, which explains the relevance of testimony
about Mr. Steele’s communications regarding his reports with Mr. Kramer, who received the
reports (including CIR 112) from Mr. Steele and Defendants and provided the memoranda to
other parties and BuzzFeed. For the same reasons, documents relating to these communications
are relevant to this Action and should be produced. The date range of this request is from the
month (September) in 2016 that CIR 112 was completed through November (when Mr. Steele
communicated and met with Mr. Kramer regarding the reports) and December (when Mr.
Kramer allowed BuzzFeed to copy the Dossier) until the date that BuzzFeed published the
Dossier on the internet (January 10, 2017).
No. 10: Documents within the period 01 July 2016 to 10 January 2017 relating to the
drafting and compilation of CIR 112; notes, research, investigative files used in the drafting of
CR112; and drafts or different versions of CIR 112.
Relevance: As set forth in Paragraph 18, No. 7, supra, Defendants engaged Orbis and
Mr. Steele to conduct research relating to Russian interference in the 2016 election. During the
course of that research and as part of the same project, at Defendants’ request, Mr. Steele and
Orbis prepared and compiled a memo, CIR 112, whose subjects are Plaintiffs and Alfa, and Mr.
Steele transmitted it to Defendants on or about September 14, 2016. Defendants had
conversations with Mr. Steele regarding the content of CIR 112 and the factual support for the
statements therein. Further, Mr. Steele took notes regarding factual support for CIR 112, but
26
claims to have destroyed such notes. 36 Plaintiffs should be entitled to documents and
communications relating to the drafting or compilation of CIR 112 (and the factual support
therefor). Such documents are directly relevant to the issues in the Action, including the falsity
of the statements about Plaintiffs, and the negligence or recklessness in publication of such
statements. The date range of this request is from the month (July) in 2016 37 that Mr. Steele and
Orbis were asked by Defendant to conduct research regarding Alfa and Plaintiffs and to prepare
a report (CIR 112) through the months that CIR 112 was completed and Mr. Steele met with and
communicated with third parties regarding the research and reports until the date that BuzzFeed
published the Dossier on the internet (January 10, 2017).
and Defendants, Mr. Kramer, Mr. Winer, reporters and members of the media, or others
regarding the delivery, transmission, or disclosure of CIR 112.
Relevance: As set forth in Paragraph 18, No. 8, supra, Orbis, Mr. Steele, and
Defendants disclosed or transmitted CIR 112 to various people and entities in 2016, which is
relevant to the issue of publication. Defendants should be entitled to any documents relating to
these disclosures. The date range of this request is from the month (September) in 2016 that CIR
112 was completed through the months that CIR 112 was disseminated and disclosed to third
parties until the date that BuzzFeed published the Dossier on the internet (January 10, 2017).
No. 12: Communications within the period 01 July 2016 to 10 January 2017 (including
documents referencing or referenced in such communications) between Mr. Steele and
Defendants, Mr. Kramer, Mr. Winer, reporters and members of the media, or others concerning
the steps taken by Mr. Steele, Orbis, or Defendants to corroborate, verify, or investigate the
information and statements about Plaintiffs in CIR 112.
36
See Ex. G, U.K. Judgment at ¶ 175 (Mr. Steele kept “manuscript notes” relating to factual support for CIR 112
and “then destroyed them” after drafting the memorandum).
37
Id. at ¶ 87.
27
Relevance: As set forth in Paragraph 18, No. 9, supra, steps taken by Mr. Steele, Orbis
or Defendants to corroborate, verify, or investigate the statements in CIR 112 relate to the falsity
of the statements in CIR 112 and to Defendants’ role and fault in disseminating and publishing
CIR 112, which are relevant issues in this Action. Defendants had conversations with Mr. Steele
regarding “the content of CIR 112, the quality of the sourcing, the competence of Mr. Steele’s
team, the potential for misinformation, and efforts to verify the information in CIR 112”—all of
which is relevant to the issues in the Action. And Mr. Steele, at one time, had notes relating to
the factual support for CIR 112. Plaintiffs should be entitled to relevant documents relating to
steps taken to corroborate, verify, or investigate the statements in CIR 112. The date range of this
request is from the month (July) in 2016 that Mr. Steele and Orbis were asked by Defendant to
conduct research regarding Alfa and Plaintiffs and to prepare a report (CIR 112) through the
months that CIR 112 was completed and Mr. Steele met with communicated with third parties
regarding the research and reports until the date that BuzzFeed published the Dossier on the
internet (January 10, 2017).
No. 13: Documents concerning the destruction, return, or non-retention of documents

within the period 01 July 2016 to the present in respect to: (a) CIR 112, including work product,
memoranda, source information, drafts or analysis relating thereto; (b) communications between
Mr. Steele and Defendants Simpson or Fusion in respect to CIR 112; and (c) engagement
agreements between Orbis and/or Mr. Steele on one hand and Fusion on the other which govern
the creation or promotion of CIR 112.
Relevance: As set forth in Paragraph 18, No. 10, supra, Defendants and Mr. Steele have
previously indicated that they destroyed or did not retain documents relating to CIR 112 that are
relevant to this Action. Defendants have produced no documents relating to CIR 112.
Documents relating to this destruction or non-retention of relevant documents should be
produced to Plaintiffs. The date range of this request is from the month (July) in 2016 that Orbis
Business Intelligence Ltd. (“Orbis”), Steele and Orbis were asked by Defendant to conduct
28
research regarding Alfa and Plaintiffs and to prepare a report (CIR 112) until the present, as there
was an ongoing duty to preserve any relevant documents from the time that litigation could have
been anticipated.
No. 14: Communications within the period 01 April 2016 to 03 October 2017 (including
documents referencing or referenced in such communications) between Mr. Steele and Igor
Danchenko regarding Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in CIR 112.
Relevance: As set forth in Paragraph 18, No. 11, supra, Mr. Danchenko was a source for
Mr. Steele’s research and reports. Documents, including communications, between Mr.
Danchenko and Mr. Steele regarding Plaintiffs, Alfa, and CIR 112 are relevant to the reliability
of the research, Defendants’ knowledge of Mr. Danchenko as a source, the falsity of the
statements in CIR 112, and whether Defendants’ publication was done negligently or
recklessly—relevant issues in this Action. The date range is explained above in No. 3.
B. Orbis Business Intelligence Ltd.
20. Documentary Evidence from Orbis. Orbis was engaged to prepare CIR 112
and Mr. Steele is a co-founder and director of Orbis. Thus, similar document requests to those
made of Mr. Steele are being made to Orbis, to the extent only that relevant documents are in the
possession, custody, or control of Orbis (and not Mr. Steele). For the avoidance of doubt,
Plaintiffs are not seeking duplicative production of the same documents. The request is limited
to the additional relevant documents that are not produced by Mr. Steele. Accordingly, as
indicated below, the relevance explanations applicable to Mr. Steele are also generally applicable
to Orbis. It is expected that Orbis will be able to provide relevant and material documentary
evidence on a number of topics. The documents requested from Orbis, and the relevance to this
Action of each request, is set forth below:
29
No. 1: Documents setting out the terms of Orbis’s and/or Mr. Steele’s engagement with
or retention by Fusion in connection with the compilation or preparation of CIR 112 and its
promotion.
No. 2. Documents setting out the scope and purpose of the work that Orbis and Mr.
Steele were to perform in connection with the compilation or preparation of CIR 112 and its
promotion.
Relevance: See Paragraph 18, No. 2, and Paragraph 19, Nos. 1 and 2, supra, which set
forth the relevance of these documents also being requested of Mr. Steele.
No. 3: Communications between Orbis or Mr. Steele and Defendants Glenn Simpson or
Fusion (including documents referencing or referenced in such communications) regarding
Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in CIR 112, within the period 01
April 2016 to 03 October 2017.
Relevance: See Paragraph 18, No. 3, and Paragraph 19, No. 3, supra, which set forth the
relevance of these documents also being requested of Mr. Steele.
No. 4: Communications between Orbis or Mr. Steele and Jonathan Winer (including
documents referencing or referenced in such communications) regarding Plaintiffs, Alfa, CIR
112, or the statements about Plaintiffs in CIR 112, within the period 01 September 2016 to 10
January 2017.

(including documents referencing or referenced in such communications) between Orbis or Mr.
Steele and Mr. Winer relating to meetings regarding Plaintiffs, Alfa, CIR 112, or the statements
about Plaintiffs in CIR 112, including the meeting between Mr. Steele and U.S. Department of
State officials and Mr. Winer on or about 11 October 2016.
Relevance: See Paragraph 18, No. 4, and Paragraph 19, Nos. 4 and 5, supra, which set

Steele and the New York Times, the New Yorker, the Washington Post, Yahoo! News, CNN,
Mother Jones and/or BuzzFeed, relating to meetings regarding Plaintiffs, Alfa, CIR 112, or the
statements about Plaintiffs in CIR 112, including the meeting between Mr. Steele and Michael
Isikoff and Jane Mayer at the Tabard Inn on or about 22 September 2016.

Steele and the New York Times, the New Yorker, the Washington Post, Yahoo! News, CNN,
30
Mother Jones, and/or BuzzFeed regarding Plaintiffs, Alfa, CIR 112, or the statements about
No. 8: Communications (including documents referencing or referenced in such

communications) between Orbis or Mr. Steele and David Corn of Mother Jones via Skype on 31
October 2016 regarding Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in CIR 112.
Relevance: See Paragraph 18, No. 5, and Paragraph 19, Nos. 6, 7, and 8, supra, which set

Steele and David Kramer regarding Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs
in CIR 112, including text messages or other types of messages between Mr. Steele and Mr.
Kramer on or about 29 December 2016.
Relevance: See Paragraph 18, No. 6, and Paragraph 19, No. 9, supra, which set forth the
relevance of these documents also being requested of Mr. Steele.
No. 10: Documents within the period 01 July 2016 to 10 January 2017 relating to the
drafting and compilation of CIR 112; notes, research, investigative files used in the drafting of
CR112; and drafts or different versions of CIR 112
Relevance: See Paragraph 18, No. 7, and Paragraph 19, No. 10, supra, which set forth
the relevance of these documents also being requested of Mr. Steele.
Steele and Defendants, Mr. Kramer, Mr. Winer, reporters and members of the media, or others
No. 12: Communications within the period 01 July 2016 to 10 January 2017 (including
documents referencing or referenced in such communications) between Orbis or Mr. Steele and
Defendants, Mr. Kramer, Mr. Winer, reporters and members of the media, or others concerning
the steps taken by Mr. Steele, Orbis, or Defendants to corroborate, verify, or investigate the
information and statements about Plaintiffs in CIR 112.
31
No. 13: Documents concerning the destruction, return, or non-retention of documents

within the period 01 September 2016 to the present in respect to: (a) CIR 112, including work
product, memoranda, source information, drafts or analysis relating thereto; (b) communications
between Orbis or Mr. Steele and Defendants Simpson or Fusion in respect to CIR 112; and (c)
engagement agreements between Orbis and/or Mr. Steele on one hand and Fusion on the other
which govern the creation or promotion of CIR 112.
C. Christopher Burrows
21. Oral Examination of Mr. Burrows. Orbis was engaged to prepare CIR 112. Mr.
Burrows is a co-founder and director of Orbis, like Mr. Steele, and was involved in aspects of
Orbis’s and Mr. Steele’s election-related research and reports done for Fusion in 2016. It is
expected that Mr. Burrows will be able to provide crucial and relevant testimony on a number of
topics on which Mr. Steele may be unable to provide testimony. Those topics, and the relevance
of each, are set forth below:
No. 1: In general terms, Mr. Burrows’s educational background, employment history,

professional qualifications and personal preparation for the examination (including contacts with
the parties, their lawyers, insurers, or representatives), excluding any privileged communications
or confidential details regarding any government service.
Relevance: Mr. Burrows was the co-founder of Orbis, which was engaged by Fusion
and prepared CIR 112 which included the defamatory statements. Mr. Burrows is identified by
Defendants as “likely to have discoverable information that Defendants may use to support their
claims or defenses” in this Action. Ex. C, Defendants’ Initial Disclosures, Section 1. Mr.
Burrows’s general educational and employment background are relevant to his credibility as a
witness and to the credibility and reliability of the research at issue in this Action which was
32
compiled and produced by Orbis. This background information is also relevant to his exercise of
decision-making authority as to content that was included in CIR 112. 38 Plaintiffs should be
entitled to ask Mr. Burrows general background questions to probe the basis for the exercise of
his decision-making authority, to provide context to his qualifications and credibility as a
witness, and to assess the credibility and reliability of Orbis’s research at issue in this Action.
No. 2: The drafting and compilation in 2016 of CIR 112 and its promotion.
Relevance: Mr. Burrows’s testimony regarding the drafting and compilation of CIR 112
and the factual support therefor is relevant to the issues in the Action such as the falsity of the
statements about Plaintiffs and the negligence or recklessness in publication of such statements.
Defendants acknowledge engaging Orbis, which Mr. Burrows co-founded, to “look into
then-candidate Trump’s activities in Russia, in support of Defendants’ ongoing research
activities” and that Burrows was one of the people at Orbis with whom “Defendants mainly
communicated.” Ex. F, Defendants’ Answer to Plaintiffs’ Interrogatory No. 12. As part of this
engagement, Orbis produced several reports, including CIR 112. Defendant Simpson has
reported that Mr. Burrows played a role in selecting what content would be included in the
reports. 39 As set forth, page 7, note 5, supra, in 2019 the U.S. government questioned the
reliability of Steele’s reports in general, and a recent English High Court judgment determined
that the specific statements about Plaintiffs in CIR 112 are inaccurate or misleading. Therefore,
Plaintiffs should be entitled to question Mr. Burrows as to the compilation of CIR 112, decisions
regarding the content of CIR 112, and the basis for including the defamatory statements in CIR
38
See Ex. A, Crime in Progress at 77 (discussing Mr. Burrows’ role in 2016 selecting information that was included
in the Dossier), 82-84 (stating that Mr. Burrows and Mr. Steele have refused to reveal the identity of source(s) for
the information in the Dossier, and discussing the briefing of an FBI agent in July 2016 by Mr. Burrows and Mr.
Steele of their “findings and sources” for the research for Fusion).
39
Ex. A, Crime in Progress at 77 (discussing Mr. Burrows’ role in 2016 selecting information that was included in
the Dossier).
33
112. Additionally, as with Proposed Topic No. 7 for Mr. Steele, Plaintiffs should be entitled to
question Mr. Burrows as to what was intended to be conveyed by the heading of CIR 112 and the
description of Plaintiffs’ relationship with President Putin.
No. 3: The destruction, return, or non-retention of the following documents: (a) CIR 112,
including work product, memoranda, source information, drafts or analysis relating to CIR 112;
(b) communications with Defendants Glenn Simpson or Fusion in respect to CIR 112; and (c)
engagement agreements between Orbis and/or Mr. Steele on one hand and Fusion on the other
which govern the creation or promotion of CIR 112.
Relevance: As set forth in Paragraph 18, No. 10, supra, Defendants, Orbis, and Mr.
Steele have destroyed or not retained documents relating to CIR 112 that are relevant to this
Action. In the proceeding brought by Plaintiffs against Orbis under the U.K. Data Protection
Act, Mr. Steele admitted that he destroyed relevant documents regarding his research for the
Dossier and CIR 112, except for certain notes of a meeting with the FBI that was attended by Mr.
Burrows. 40 And Defendants have produced no documents relating to CIR 112. Plaintiffs should
be entitled to question Mr. Burrows to determine when documents were destroyed, whether it
was at the direction of Defendants, and whether it was done when litigation should have been
anticipated. Plaintiffs should also be entitled to question Mr. Burrows as to why certain
documents were retained (such as certain meeting notes) but not other documents.
No. 4: Delivery, transmission, or disclosure of CIR 112 in 2016 to other persons or

entities, including Defendants, David Kramer, Jonathan Winer, reporters and members of the
media.
Relevance: See Paragraph 18, No. 8, supra, which sets forth the relevance of testimony
on this topic also being requested of Mr. Steele. For the same reasons, Plaintiffs should be
entitled to testimony from Mr. Burrows, who was Mr. Steele’s partner at Orbis and privy to the
research in CIR 112 and the dissemination thereof. Mr. Burrows was present at meetings in
40
See Ex. G, U.K. Judgment at ¶¶ 51, 81 (reflecting the meeting in July 2016).
34
which the research findings in the reports were discussed and disclosed, played a role in deciding
what to include in the reports, and communicated with the media and with Defendants and Mr.
Steele in 2017 after BuzzFeed published the research reports online. 41
No. 5: The steps taken by Mr. Burrows, Mr. Steele, Orbis, or Defendants to corroborate,
verify or investigate the information and statements about Plaintiffs in CIR 112.
CIR 112, which are relevant issues in this Action. For the same reasons, Plaintiffs should be
entitled to testimony on these issues from Mr. Burrows, who was Mr. Steele’s partner at Orbis
and privy to the research in Orbis’s reports (which included CIR 112).
D. Edward Baumgartner
22. Oral Examination of Mr. Baumgartner. As indicated in Part II, paragraph 14,
supra, Defendants have specifically identified Mr. Baumgartner as an individual likely to have
information relevant to this Action and Defendants’ claims and defenses, including, the “research
related to matters in CIR 112”; “Plaintiffs’ conduct”; “Plaintiffs’ ties, communications, meetings,
and relations with the Kremlin, Vladimir Putin, and those representing them or acting on their
behalf”; and “Alfa’s ties to the Kremlin and Vladimir Putin.” Ex. C, Defendants’ Initial
Disclosures, Section 1. It is expected that Mr. Baumgartner will be able to provide relevant and
crucial testimony on a number of topics. Those topics, and the relevance of each, are set forth
below:
41
Id. See also Ex. A, Crime in Progress at 10, 148 (Mr. Burrows was confronted by a reporter after BuzzFeed
published the reports online, and Mr. Burrows then communicated with Defendants and Mr. Steele about the
dissemination of the reports.); 125, 133 (Mr. Burrows and Mr. Steele met with U.K. officials in November and
December 2016 to discuss their research findings and the content of the reports); 205 (In September 2017, Mr.
Burrows and Mr. Steele met in London with FBI agents and U.S. prosecutors to discuss the research findings.).
35
No. 1: In general terms, Mr. Baumgartner’s educational background, employment

history, professional qualifications and personal preparation for the examination (including
contacts with the parties, their lawyers, insurers, or representatives), excluding any privileged
communications or confidential details regarding any government service.
Relevance: Mr. Baumgartner played a role in the research that Fusion was engaged to
conduct which led to the reports compiled by Orbis (including CIR 112). Mr. Baumgartner’s
general educational and employment background are relevant to his credibility as a witness and
to the credibility and reliability of the research at issue in this Action. Plaintiffs should be
entitled to ask Mr. Baumgartner general background questions to provide context to his
qualifications and credibility as a witness, and to assess the credibility and reliability of the
research at issue in this Action.
No. 2: The nature and terms of Mr. Baumgartner’s, and/or his firm’s, engagement by
Fusion in 2016 relating to Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in CIR
112, and the scope and purpose of the engagement.
Relevance: Defendants have identified Mr. Baumgartner as likely to have information
relevant to the issues in this Action, including the research relating to the statements about
Plaintiffs in CIR 112, as well as Plaintiffs’ conduct and the relationships between Plaintiffs and
Alfa and the Kremlin or Putin, which are the subject of CIR 112. In addition, Defendant
Simpson has indicated that Mr. Baumgartner assisted Defendant Fusion in 2016 as a
subcontractor in connection with the election-related research. 42
As set forth in Paragraph 18, No. 2, supra, regarding the relevance of Defendants’
retention of Orbis, the scope and purpose of Defendants’ retention of Mr. Baumgartner in
connection with the election-related research in 2016 is relevant to issues in this Action, such as
the falsity of the statements in CIR 112, the motives for the research and publication, and
42
Ex. I, Transcript of Interview of Glenn Simpson dated August 22, 2017, U.S. Senate Judiciary Committee, at 83-
85, 103, 189.
36
whether the publication was negligent or reckless. Accordingly, Plaintiffs should be entitled to
testimony from Mr. Baumgartner on these issues.
No. 3: Mr. Baumgartner’s research regarding Plaintiffs, Alfa, CIR 112, or the statements
about Plaintiffs in CIR 112.
relevant to the issues in this Action, including the research relating to the statements about
Plaintiffs in CIR 112, as well as Plaintiffs’ conduct and the relationships between Plaintiffs and
Alfa and the Kremlin or Mr. Putin, which are the subject of CIR 112. If any pre-2016 research
was relied upon or used in connection with CIR 112, such research would also be relevant.
Mr. Baumgartner’s research and/or knowledge regarding Plaintiffs, Alfa, CIR 112, and
the statements in CIR 112, are relevant to issues in this Action, such as whether the defamatory
statements are false and whether the Defendants acted negligently or recklessly in publishing the
statements. See Paragraph 18, No. 2, supra (summarizing the legal standards and issues in this
Action). Plaintiffs should be entitled to testimony from Mr. Baumgartner regarding these issues.
No. 4: Preparation of Mr. Baumgartner’s report titled “ALFA Dossier Open Sources.”
Relevance: In response to Interrogatory No. 18 (Ex. F), which asks Defendants to
identify any documents or evidence reflecting or demonstrating any “questionable, unethical and
illegal conduct” by Plaintiffs concerning “the entanglement of Russian oligarchs’ political and
business interests and those of the Russian state and/or President Putin,” as referenced in their
Affirmative Defenses, Defendants identify a document entitled “Report re: ALFA Dossier Open
Source” (“Dossier Alfa Report”) and Mr. Baumgartner as the author.
Plaintiffs should be entitled to testimony from Mr. Baumgartner regarding this document
being relied upon by Defendants in this Action (as support for the statements in CIR 112 or
37
otherwise), which is relevant to whether the defamatory statements are false and whether the
Defendants acted negligently or recklessly in publishing the statements.
No. 5: Communications in 2016 or 2017 between Mr. Baumgartner and Defendants

Glenn Simpson or Fusion regarding the report titled “ALFA Dossier Open Sources.”
No. 6: Communications in 2016 or 2017 between Mr. Baumgartner and Defendants

Simpson or Fusion regarding Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in CIR
112.
relevant to the issues in this Action, have acknowledged retaining and communicating with Mr.
Baumgartner in 2016 relating to the election-related research, and have cited the Dossier Alfa
Report as a document on which they will rely in this Action. Plaintiffs should be entitled to
testimony from Mr. Baumgartner regarding his communications with Defendants about
Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in CIR 112, and the timing of such
communications, which are relevant to issues in this Action (such as the falsity of the defamatory
statements and the fault in publishing the statements).
23. Documentary Evidence from Mr. Baumgartner. It is expected that Mr.
Baumgartner will be able to provide relevant and material documentary evidence on a number of
topics. The documents requested from Mr. Baumgartner, and the relevance of each request, is
set forth below:
No. 1: Documents setting out the terms and scope of Mr. Baumgartner’s engagement by
Fusion relating to Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in CIR 112 or its
promotion.
Relevance: For the same reasons that testimony from Mr. Baumgartner on the issues of
his engagement by Fusion and the scope and purposes of the work to be performed are relevant
in this Action, as set forth in Paragraph 22, No. 2, supra, documentary evidence relating to these
issues are relevant and should be produced.

38
No. 2: Documents within the period 01 April 2016 to 03 October 2017 related to the
preparation of the report titled “ALFA Dossier Open Sources.”
Relevance: See Paragraph 22, No. 4, supra, which indicates the relevance of testimony
from Mr. Baumgartner regarding his preparation of the Dossier Alfa Report (on which
Defendants rely in this Action). For the same reasons, documents relating to the preparation of
this report should be produced by Mr. Baumgartner. The date range of this request is from April
2016 (the month Fusion was retained in 2016 for the election related research) until the date
Plaintiffs filed their complaint in this Action.
No. 3: Communications within the period 01 April 2016 to 03 October 2017 between Mr.
Baumgartner and Defendants Glenn Simpson or Fusion regarding the report titled “ALFA
Dossier Open Sources.”
No. 4: Communications within the period 01 April 2016 to 03 October 2017 between Mr.
Baumgartner and Defendants Simpson or Fusion regarding Plaintiffs, Alfa, CIR 112, or the
statements about Plaintiffs in CIR 112.
Relevance: See Paragraph 22, Nos. 5 and 6, which indicates the relevance of testimony
from Mr. Baumgartner regarding his communications with Defendants regarding his preparation
of the Dossier Alfa Report (on which Defendants rely in this Action) and regarding Plaintiffs,
Alfa, CIR 112, or the statements about Plaintiffs in CIR 112. For the same reasons, documents
relating to these communications are relevant to issues in this Action and should be produced by
Mr. Baumgartner. The date range is explained above in No. 2.
No. 5: Documents regarding Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs
in CIR 112, within the period 01 April 2016 to 03 October 2017.
Relevance: See Paragraph 22, No. 3, supra, which sets forth the relevance of testimony
from Mr. Baumgartner regarding his research relating to Plaintiffs, Alfa, CIR 112, or the
statements about Plaintiffs in CIR 112. Mr. Baumgartner’s documents relating to these topics
39
are similarly relevant and should be produced to Plaintiffs. The date range is explained above in
No. 2.
E. Sir Andrew Wood
24. Oral Examination of Sir Andrew Wood. As indicated in Part II, paragraph 15,
supra, Defendants have specifically identified Sir Andrew Wood as an individual likely to have
information relevant to this Action and Defendants’ claims and defenses, including the “receipt
and delivery of CIR 112.” Ex. C, Defendants’ Initial Disclosures, Section 1. It is expected that
Sir Andrew Wood will be able to provide relevant and crucial testimony on a number of topics.
Those topics, and the relevance of each, are set forth below:
No. 1: In general terms, Sir Andrew Wood’s educational background, employment

history, professional qualifications and personal preparation for the examination (including
contacts with the parties, their lawyers, insurers, or representatives), excluding any privileged
Relevance: Sir Andrew Wood communicated with Mr. Steele and others relating to CIR
112 and Mr. Steele’s research, and vouched for Mr. Steele’s reliability in the context of the
election-related research and reports. 43 Sir Andrew Wood’s general educational and
employment background are relevant to his credibility as a witness and to the credibility and
reliability of Mr. Steele’s research at issue in this Action. Plaintiffs should be entitled to ask Sir
Andrew Wood general background questions to provide context to his qualifications and
credibility as a witness, and to assess the credibility and reliability of the research at issue in this
Action.
No. 2: Communications in 2016 and 2017 between Sir Andrew Wood and Christopher
Steele regarding Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in CIR 112,
including in September 2016 around the time that Mr. Steele and Orbis transmitted CIR 112 to
Defendant Fusion.
43
See Ex. A, Crime in Progress at 127 (after being briefed by Sir Andrew Wood about Mr. Steele’s reports, Senator
McCain sent David Kramer to London to meet with Mr. Steele after being “[r]eassured by [Sir Andrew] Wood that
Steele was reliable”).
40
Relevance: Defendants have identified Sir Andrew Wood as likely to have information
relevant to the issues in this Action, specifically the receipt and delivery of CIR 112. Defendant
Simpson has indicated that Sir Andrew Wood was a mentor to Mr. Steele who Mr. Steele
contacted in September 2016 (around the time that Mr. Steele completed and transmitted CIR
112 to Fusion) to “seek his advice and share the intelligence he had gathered.” 44 Sir Andrew
Wood’s communications with Mr. Steele regarding his research and CIR 112 is relevant to the
falsity of the statements in CIR 112, the motives for the research and publication, and whether
the publication was negligent or reckless. Accordingly, Plaintiffs should be entitled to testimony
from Sir Andrew Wood on these issues.
No. 3: Communications and meetings in 2016 and 2017 between Sir Andrew Wood and
David Kramer or U.S. Senator John McCain regarding Plaintiffs, Alfa, CIR 112, or the
statements about Plaintiffs in CIR 112, including the meetings with Mr. Kramer and Senator
McCain in November 2016 in Halifax, Nova Scotia.
No. 4: Communications and meetings between Mr. Kramer and Mr. Steele in 2016 and
2017 regarding Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in CIR 112, including
the meeting between Mr. Kramer and Mr. Steele in London in November 2016 which Sir
Andrew Wood arranged.
Relevance: As indicated by Defendant Simpson, after Sir Andrew Wood had been
briefed by Mr. Steele regarding the research in the reports in September 2016, Sir Andrew Wood
encouraged Mr. Steele to disclose the reports to government officials. Then, in November 2016,
in Halifax, Nova Scotia, Sir Andrew Wood met with and conveyed information from Mr.
Steele’s reports to David Kramer, an advisor to Senator John McCain, and to Senator McCain.
Subsequently, after reassuring Senator McCain of Mr. Steele’s reliability, Sir Andrew Wood
arranged for Mr. Kramer to meet with Mr. Steele in London where Mr. Steele shared his reports
44
Ex. A, Crime in Progress at 107.
41
with Mr. Kramer. Mr. Kramer then obtained a copy of the reports (including CIR 112) from
Defendant Simpson. 45
Sir Andrew Wood’s dissemination of Mr. Steele’s election-related research, and his
statements about the reliability of Mr. Steele and his reports, are relevant to issues in this Action,
such as the publication of the defamatory statements, whether the defamatory statements are
false, and whether the Defendants acted negligently or recklessly in publishing the statements.
See Paragraph 18, No. 2, supra (summarizing the legal standards and issues in this Action).
Plaintiffs should be entitled to testimony from Sir Andrew Wood regarding these issues.
No. 5: The steps taken by Sir Andrew Wood, Mr. Steele, Orbis, or Defendants to
corroborate, verify or investigate the information and statements about Plaintiffs in CIR 112.
CIR 112, which are relevant issues in this Action. Mr. Steele confided in Sir Andrew Wood
regarding the election-related research and reports and Sir Andrew Wood vouched for Mr.
Steele’s reliability and communicated his research to others. Plaintiffs should be entitled to
testimony on these issues, including any corroboration or verification of the statements in CIR
112 by Sir Andrew Wood.
25. Documentary Evidence from Sir Andrew Wood. It is expected that Sir
Andrew Wood will be able to provide relevant and material documentary evidence on a number
of topics. The documents requested from Sir Andrew Wood, and the relevance of each request,
is set forth below:
45
Ex. A, Crime in Progress at 126-31.
42
between Sir Andrew Wood and Mr. Steele (including documents referencing or referenced in
such communications) regarding Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in
CIR 112, including in September 2016 around the time that Mr. Steele and Orbis transmitted
CIR 112 to Defendant Fusion and relating to the meeting between Mr. Kramer and Mr. Steele in
London in November 2016.
Relevance: As set forth in Paragraph 24, Nos. 2, 4, supra, Sir Andrew Wood’s
communications with Mr. Steele regarding the research and CIR 112 is relevant to the falsity of
the statements in CIR 112, the motives for the research and publication, and whether the
publication was negligent or reckless. Accordingly, relevant documents should be produced to
Plaintiffs.

between Sir Andrew Wood and David Kramer or U.S. Senator John McCain (including
documents referencing or referenced in such communications) regarding Plaintiffs, Alfa, CIR
112, or the statements about Plaintiffs in CIR 112, including the meetings with Mr. Kramer and
Senator McCain in November 2016 in Halifax, Nova Scotia.
Relevance: For the same reasons that testimony from Sir Andrew Wood relating to
communications with David Kramer or U.S. Senator John McCain regarding Plaintiffs, Alfa,
CIR 112, or the statements about Plaintiffs in CIR 112, is relevant, as set forth in Paragraph 24,
No. 3 supra, documentary evidence relating to these issues is relevant and should be produced.

(including documents referencing or referenced in such communications) between Sir Andrew
Wood and Mr. Steele, Mr. Kramer, Orbis, or Defendants concerning the steps taken by Sir
Andrew Wood, Mr. Steele, Orbis, or Defendants to corroborate, verify, or investigate the
information and statements about Plaintiffs in CIR 112
Relevance: As set forth in Paragraph No. 24, No. 5, supra, the steps taken by Mr. Steele,
Orbis or Defendants to corroborate, verify, or investigate the statements in CIR 112 relate to the
falsity of the statements in CIR 112 and to Defendants’ role and fault in disseminating and
publishing CIR 112, which are relevant issues in this Action. For the same reasons, Plaintiffs
should be entitled to documentary evidence on these issues.
43
26. In light of the foregoing, Plaintiffs submit that they have a need to secure for trial
the testimony of Messrs. Steele, Burrows, and Baumgartner, and Sir Andrew Wood, and
documentary evidence from Messrs. Steele and Baumgartner, and Sir Andrew Wood, and Orbis.
27. Messrs. Steele, Burrows, and Baumgartner, and Sir Andrew Wood are British
citizens residing in London in the United Kingdom, and Orbis is a company organized under the
laws of the United Kingdom. Messrs. Steele, Burrows, and Baumgartner, and Sir Andrew
Wood, and Orbis, therefore, are beyond the jurisdiction of this or any U.S. Court and Plaintiffs
will not be able to compel production of evidence from them for use at trial.
28. Mr. Steele and Orbis are parties to a proceeding brought in the Superior Court of
the District of Columbia and subsequently appealed to the D.C. Court of Appeals relating to the
same subject matter (the “Steele D.C. Matter”). 46 Mr. Steele and Orbis appeared in both of those
courts and are represented by counsel in that matter. Plaintiffs attempted to secure, through
counsel who represents Mr. Steele and Orbis in the Steele D.C. Matter, their consent to the
service of subpoenas issued to Mr. Steele, Mr. Burrows, and Orbis by Plaintiffs pursuant to Rule
45 in connection with this Action. U.S. counsel for Mr. Steele and Orbis declined to accept
service of subpoenas on behalf of Mr. Steele, Mr. Burrows, and Orbis and directed Plaintiffs to
utilize Hague Convention procedures to obtain discovery from Mr. Steele and Orbis. Ex. J,
emails dated May 8, 2020 and May 18, 2020, and Ex. K, emails dated July 15-16, 2020.
Plaintiffs have provided U.S. counsel for Mr. Steele, Mr. Burrows, and Orbis with notice of this
application and have provided their counsel with all relevant papers by email.
46
The counsel identified for Mr. Steele and Orbis represents them in connection with the proceeding captioned
Khan v. Orbis Business Intelligence Ltd., Case No. 18-CV-0919. That case was originally brought in the Superior
Court of the District of Columbia, which dismissed it based on a local statute known as the D.C. Anti-SLAPP Act.
Its current posture involves the drafting of a petition by Plaintiffs to the United States Supreme Court. Mr. Steele
and Orbis are not parties to the Action in connection with which this Request is made.
44
29. Plaintiffs are not aware of any counsel or representative for Mr. Baumgartner in
the United States. U.K. counsel for Plaintiffs wrote to Mr. Baumgartner directly at his Edward
Austin business address (copied to the business email address) and asked whether Mr.
Baumgartner would voluntarily produce documentary evidence and appear for an examination.
Plaintiffs will update the Court as to any response received from Mr. Baumgartner.
30. Plaintiffs are not aware of any counsel or representative for Sir Andrew Wood in
the United States. U.K. counsel for Plaintiffs wrote to Sir Andrew directly at his Chatham House
business address (copied to the gmail email address given on Sir Andrew’s Chatham House
online biography) and asked if Sir Andrew Wood would voluntarily produce documentary
evidence and appear for an examination. Plaintiffs will update the Court as to any response
received from Sir Andrew Wood.
31. To ensure that Plaintiffs can take the depositions of Messrs. Steele, Burrows, and
Baumgartner, and Sir Andrew Wood and preserve their testimony for trial, and to ensure the
preservation of relevant and material documentary evidence from Messrs. Steele and
Baumgartner, Sir Andrew Wood, and Orbis, Plaintiffs ask this Court to issue the accompanying
Letter of Request for International Judicial Assistance to the High Court (Queen’s Bench
Division) of England and Wales to compel the testimony of Christopher Steele, Christopher
Burrows, Edward Baumgartner, and Sir Andrew Wood, and to compel the production of
documentary evidence from Messrs. Steele and Baumgartner, Sir Andrew Wood, and Orbis.
Dated: Washington, D.C.

August 4, 2020
Respectfully submitted,
/s/ Kim Sperduto

Alan S. Lewis (#NY0252)
45
2 Wall Street
New York, NY 10005
Tel: (212) 732-3200
Fax: (212) 732-3232
lewis@clm.com
-and-
Kim Sperduto (DC Bar No. 416127)

SERDUTO THOMPSON & GASSLER PLC
Tel: (202) 408-8900
Fax: (202) 408-8910
ksperduto@stglawdc.com
46
I hereby certify that a true and correct copy of the foregoing was served electronically via
the CM/ECF electronic filing system on all counsel or parties of record this 4th day of August,
2020.
/s/ Kim Sperduto

Kim Sperduto
47

------------------------------------------------------------- X
GERMAN KHAN, :
:
Plaintiffs,
:
:
v. Case No. 1:17-cv-02041 (RJL)
:
:
BEAN LLC (a/k/a FUSION GPS) and GLENN
:
SIMPSON,
:
:
Defendants. :
------------------------------------------------------------- X
DECLARATION OF ALAN S. LEWIS IN SUPPORT OF

MOTION FOR ISSUANCE OF LETTER OF
REQUEST FOR INTERNATIONAL JUDICIAL ASSISTANCE
I, Alan S. Lewis, declare under penalty of perjury as follows:
1. I am an attorney duly licensed to practice law in this Court. I am a partner at the
law firm of Carter Ledyard & Milburn LLP, and represent Plaintiffs Mikhail Fridman, Petr
Aven, and German Kahn, in the above-captioned case.
2. This Declaration is submitted in support of Plaintiffs’ motion for the issuance of a
letter of request for international judicial assistance to the Senior Master of the High Court
(Queen’s Bench Division) of England and Wales, in order to obtain oral testimony and/or
documentary evidence from Christopher Steele, Christopher Burrows, Edward Baumgartner, Sir
Andrew Wood, and Orbis Business Intelligence Ltd., each of whom is located in the United
Kingdom of Great Britain and Northern Ireland. I am fully familiar with the facts and
circumstances of this case.
9701351.3
3. Annexed hereto as Exhibit A is a true and correct copy of excerpts of the book
titled Crime in Progress, Inside the Steele Dossier and the Fusion GPS Investigation of Donald
Trump (2019), authored by Defendant Glenn Simpson and Peter Fritsch.
4. Annexed hereto as Exhibit B is a true and correct copy of Plaintiffs’
Supplemental Response to Defendants’ Interrogatory No. 2, dated May 18, 2020.
5. Annexed hereto as Exhibit C is a true and correct copy of Defendants’ First
Amended Rule 26(a)(1) Initial Disclosures, dated May 18, 2020.
6. Annexed hereto as Exhibit D is a true and correct copy of excerpts of the report
titled Review of Four FISA Applications and Other Aspects of the FBI’s Crossfire Hurricane
Investigation (Dec. 2019) from the Officer of the Inspector General Michael Horowitz, U.S.
Department of Justice, available at https://www.justice.gov/storage/120919-examination.pdf.
7. Annexed hereto as Exhibit E is a true and correct copy of the U.S. Senate
Judiciary Committee Release, dated July 17, 2020, available at
https://www.judiciary.senate.gov/press/rep/releases/judiciary-committee-releases-declassified-
documents-that-substantially-undercut-steele-dossier-page-fisa-warrants.
8. Annexed hereto as Exhibit F is a true and correct copy of Defendants’ Revised
Answers to Plaintiffs’ First Set of Interrogatories and Answers to Plaintiffs’ Second Set of
Interrogatories, dated May 18, 2020.
9. Annexed Document
Case 1:17-cv-02041-RJL hereto as90-2
Exhibit
FiledG is a truePage
08/04/20 and2correct
of 191 copy of excerpts of the U.K.
High Court Judgment dated July 8, 2020 in Aven and others v. Orbis Business Intelligence Ltd.,
[2020] EWHC 1812 (QB), available at
https://www.bailii.org/ew/cases/EWHC/QB/2020/1812.html.
9701351.3
10. Annexed hereto as Exhibit H is a true and correct copy of an op-ed article
entitled Devin Nunes is investigating me. Here’s the truth, Wash. Post, Feb. 8, 2018, authored by
Jonathan M. Winer.
11. Annexed hereto as Exhibit I is a true and correct copy of excerpts of the
transcript of the interview of Glenn Simpson dated August 22, 2017 before the U.S. Senate
Judiciary Committee.
12. Annexed hereto as Exhibit J is an email dated May 8, 2020 from me, as counsel
for Plaintiffs, to Christy Hull Eikhoff of the law firm of Alston & Bird, U.S. counsel for
Christopher Steele and Orbis Business Intelligence Ltd., and from Ms. Eickhoff to me dated May
18, 2020, which reflect Plaintiffs’ request that Ms. Eickhoff accept service of subpoenas on
behalf of Mr. Steele and Orbis and her refusal to do so, indicating that Plaintiffs must seek
documents or testimony from such parties via the Hague Convention procedures.
13. Annexed hereto as Exhibit K is an email exchange dated July 15-16, 2020 from
me, as counsel for Plaintiffs, to Christy Hull Eikhoff of the law firm of Alston & Bird, U.S.
counsel for Christopher Steele and Orbis Business Intelligence Ltd., and from Ms. Eickhoff to
me, which reflect Plaintiffs request that Ms. Eickhoff accept service of subpoenas on behalf of
Mr. Burrows and her refusal to do so, indicating that Plaintiffs must seek documents or
testimony from such parties via the Hague Convention procedures.
14. Annexed Document

Case 1:17-cv-02041-RJL hereto as90-2
Exhibit
FiledL is a truePage
08/04/20 and3correct
of 191 copy of Company Intelligence
Report 112 prepared by former British intelligence agent Christopher Steele, as posted to the
internet by BuzzFeed.
15. Annexed hereto as Exhibit M is a true and correct copy of excerpts of
Defendants’ Closing Submissions in the proceedings captioned Aleksej Gubarev and another v.
9701351.3
(i) Orbis Business Intelligence Limited and (ii) Christopher Steele, Claim No. HQ17D00413, in
the High Court of Justice, Queen’s Bench Division.
16. Annexed hereto as Exhibit N is a true and correct copy of an article entitled The
F.B.I. Pledged to Keep a Source Anonymous. Trump Allies Aided His Unmasking, NY Times,
July 25, 2020.
Pursuant to 28 U.S.C. §1746, I declare under penalty of perjury that the foregoing
is true and correct.
Executed on August 4, 2020
____________________________
Alan S. Lewis
9701351.3
EXHIBIT A
0i
II E
PlUG 5 I
INSIDE THE T ELE DOSSIER AND

THE FUSIO PS INVESTIGATION
OF DONALD TRUMP
and
Co-founders of fusion OPS
• t~~tlii,.. 011.0
1,0 I.,.’
II il..i 0
. go I,
• • Dli.
O lou, 1..o ••
Dlxii.. 00 000
1 I • I 0 I’D
Ox
o ~
10
.,., I.
• I - - - ee.
“I THINK WE HAVE A PROBLEM” 5
Democratic National Committee. Fusion began to wonder if these

events were related.
Steele’s task was to tap his Russian source network to answer some
nagging questions arising from the information on Trump that Fusion
had already gathered: Why had Trump made so many trips to Russia
over the years, without ever getting a single development project off the
ground? Why did so many threads in the Trump story lead to Moscow
and figures close to Putin? And why was Trump so smitten with Putin,
who seemed fond of Trump in return?
Simpson had spent fifteen years in Washington and Europe as a Wall
Street Journal investigative reporter, focusing much of his work on the
emerging scourge of transnational crime. To his surprise, some of the
characters from the ex—Soviet Union who surfaced in the initial phase of
Fusion’s investigation of Trump were people he had written about a de
cade earlier while investigating Russian corruption and organized crime
for the Journal, stories Fritsch had edited while the two worked in Brus
sels.
Simpson wasn’t completely surprised by the news of the Bernstein
call. He told Fritsch that he had recently heard from a friend at The
Washington Post that Fred Hiatt, the paper’s editorial page editor, was
talking about some sensational memoranda that sounded a lot like
Steele’s work.
Someone was leaking—that was clear. This had the potential to be a
big problem.
The Steele reports—soon to be known as “the dossier”—were field
intelligence from one of the West’s most senior Russia watchers. The
memos he produced were never meant to be viewed outside of a tiny
circle of people, much less shared with the public. In unredacted form,
the reports could expose Steele’s sources and jeopardize lives. Steele
took great care to mask those sources in his reports to Fusion. Still, the
information clearly came from people with extraordinary access in Rus
sia, and Russian intelligence could figure out who they were and track
them down. Those sources included a number of people inside Russia
and field operatives outside the country who needed protecting at all
costs. Unredacted memos flying around among the Washington press
corps risked exposing people to real danger.
Given the control Fusion had maintained over the memos, there was
only one likely suspect for the leak: David Kramer, a longtime adviser to
Republican senator John McCain.
6 I CRIME IN PROGRESS
At Steele’s urging, Simpson had provided a set of the memos to

Kramer a few weeks after the election. This was done for the sole pur
pose of passing them to McCain, who would then provide them to the
head of the FBI. Steele had been secretly working with FBI agents for
months, trying to sound the alarm, while Simpson had provided up
dates to a longtime contact at the Justice Department. Still, the feds
seemed to be slow on the uptake, and Steele, Simpson, and Fritsch were
concerned that the information was not getting through to the top brass.
An alarmed McCain had promised to fix that.
Senator McCain, still many months from a dire brain cancer diagno
sis, wanted to put a copy of Steele’s memos in front of FBI Director James
Comey—a decision his friend and fellow Republican senator Lindsey
Graham encouraged. McCain wanted to know if the FBI was doing any
thing about credible information from a trusted ex—intelligence official
in the U.K. that a hostile foreign power might have influence over the
U.S. president-elect.
Simpson agreed to entrust Kramer with a copy of the Steele memos,
for McCain’s eyes only, because he knew that Kramer’~ dislike of Putin
ran deep. While still a reporter, Simpson had turned to Kramer as a
source a decade earlier for stories on Russia’s growing political influence
in Washington. But Kramer’s alarm was so acute that he could easily do
something rash. Lately, he had been telling associates that he still hoped
to find a way—any way—to stop Trump from being inaugurated. He
thought that exposing Trump’s Russia ties might just be the answet How
he planned to do that was unclear.
Kramer’~ theory was about to be tested.
The story blew open at 5:10 EM. on the afternoon of January 10,2017, in
a live broadcast by CNN that revealed just how far up the chain the
Steele reporting had traveled. Above the chyron “INTEL CHIEFS PRE
SENTED TRUMP WITH CLAIMS OF RUSSIAN EFFORTS TO COM
PROMISE HIM:’ a phalanx of three top CNN correspondents, plus Carl
Bernstein, announced that senior intelligence officials had appended a
two-page synopsis of some disturbing information to a classified brief
ing presented to both President Obama and President-elect Trump.
Jim Sciutto, CNN’s longtime national security correspondent, deliv
ered the overview: “Classified documents on Russian interference in the
2016 U.S. election:’ he said, had been presented to Obama and Trump.
and had backed into a ditch on a meandering dirt road high above Gey
serville. A Fusion search party later found him and freed his car.
Later, over drinks, they discussed—off the record—Trump’s docu
mented ties to Russia, setting Bensinger on a reporting trail that ulti
mately brought him to the Washington office of one David Kramer.
Simpson hung up and dialed BuzzFeed editor in chief Ben Smith.
Smith had been lured away from Politico in 2011 to run BuzzFeed, with
a mandate to make it a more serious news outfit. This was not what pros
do, Simpson screamed. “Take down those reports right now!”
Smith was implacable. The dossier had been briefed to the incoming
and outgoing presidents, he said. President Obama had ordered a mas
sive investigation of Russian interference in the election. This was all a
matter of national importance that deserved to be vetted and scruti
nized. It was the first version of the high-minded journalistic argument
he would make repeatedly in coming days to defend his decision to pub
lish source intelligence on the Internet.
Simpson argued that Smith was missing the more immediate point.
The reports could help Putin track down the sources—not just Steele,
but the sources he had relied on within Russia. There were lives at risk.
Smith said he hadn’t pondered that, but he said he had no intention of
taking the post offline. It was too late for that anyway.
Simpson and Fritsch again reached Steele on an encrypted line. It
was late in England. Steele was angry but calm. He, too, suspected that
the McCain camp had acted irresponsibly and betrayed them. Fusion
and Orbis would figure that out later. Right now, Steele had higher pri
orities. He was already making plans to, as he put it, c~ to ground”—
spy-speak for going into hiding. “Let’s reassess in the morning:’ Steele
said.
His preparations were put to use almost immediately. The following
day, January 11, Steele’s longtime partner in Orbis, a former British
agent named Christopher Burrows, received an unannounced visit at
his home outside London from a reporter for The Wall Street Journal.
Could Burrows confirm that Christopher Steele was the author of the
memoranda published in BuzzFeed? The reporter said he was on dead
line and urgently needed a comment. Burrows politely declined. A
flurry of calls ensued between Burrows, Simpson, Steele, Fritsch, and
eventually KrameL
While Kramer claimed not to know how the Journal had obtained
Steele’s name, he also said he had interceded with the Journal’s editors in
an attempt to persuade them not to publish Steele’s name, for security
trons had apparently not given up hope of somehow stopping Trump

before the Republican convention in July. One reason appeared to be
that they had been persuaded by Fusiont’s research that Trump was vul
nerable on his ties to Russia.
That view solidified with Manafort’s arrival on the scene at the end of
the month. The Free Beacon team was initially eager to expose Manafort’s
Russian entanglements and his adventures in Ukraine. Two days after
Manafort joined the Trump campaign, the Beacon posted a story on a
theme that others in the mainstream media would write about only
later: “Lawsuit: Trump Aide Funneled Mob-Linked Ukrainian Oh
garch’s Fortune into U.S. Real Estat&’ Soon, the Free Beacon’s appetite
for attacking Trump began to wane as Trump’s nominating position
grew stronger, which suggested to Fusion that even Trump’s most ardent
conservative critics were unlikely to abandon the Republican banner if
Trump emerged as their standard-bearer. Email queries slowed to a
trickle, and there was no longer the same hunger for fresh material.
On April 19, Trump took the New York primary with 59 percent of
the vote.
The next day, Simpson and Fritsch sat down in Washington with Marc
Elias, an attorney at Perkins Coie, a Seattle-based law firm with a large
political practice in D.C. on the Democratic side of the aisle. Fusion’s
Democratic contact had made the introduction to Elias, arguably the
most powerful attorney in Democratic politics. He served as general
counsel to both the Democratic National Committee and the Hillary for
America campaign. He was also personal counsel to many Democratic
senators. As a voting rights specialist, he had argued—and won—
multiple cases before the U.S. Supreme Court.
Despite his résumé, Elias is a supremely informal charactet He is a
large, balding man who looks like he could have played on the offensive
line of his favorite NFL team, the New York Giants. His shoes are sen
sible, his sentences short. He is as happy talking about his dog, Bode, as
he is discussing election law or politics. A dog bed shares space in his
office with Giants swag and framed letters of appreciation from every
Democratic senator you can name, and a few you can’t.
Elias didn’t need much convincing. He had heard of the research Fu
sion had done on Mitt Romney and Bain Capital during the 2012 cam
paign and said he needed that kind of deep research on Trump. The
NEW CLIENT I 57
existing in-house research at the DNC and the campaign was incom
plete. The campaign wanted a belt-and-suspenders approach to its re
search efforts; redundancy was tolerable if that meant the campaign
ended up with the very best information at its disposal.
Money wouldnt’t be a problem, Elias said. Clinton, the Democratic
Party; and related PACs would go on to raise over $1.2 billion for her
campaign.
Elias said the campaign knew what it needed to know about Trump
on a lot of the issues—Trump’s cynical flip-flops to a pro-life stance on
abortion rights and his latter-day opposition to a ban on assault weap
ons. Less understood, he said, was how Trump had managed to recover
from a string of bankruptcies that should have ruined him. Where did
his money come from, how much did he really have, and who helped
him? “We know what he says:’ Elias said. “We need you guys to figure
out who he is.
Fritsch disclosed that Fusion was currently engaged by an unnamed
Republican client to do research on Trump but expected that engage
ment to end soon. Simpson said the firm couldn’t share the written re
ports it had done for the Republicans but had a wealth of knowledge and
promising leads gleaned from public records that could be drawn upon
in new, general-election-focused research. Elias didn’t see a conflict or a
problem.
Elias said Fusion would be reporting only to him, which sounded
great to Fritsch and Simpson. They didn’t want to have any contact with
the campaign brass. Elias wanted it that way for legal reasons: If Fusion’s
communications were with a lawyer, they could be considered privi
leged and kept confidential. Political work like this can be perilous, pro
voking lawsuits down the road—as this job would later prove. Elias also
didn’t want Fusion drawn into the daily fire drill of a presidential cam
paign, forced to respond to the jack-in-the-box demands of political op
eratives. He wanted Fusion to focus on the big picture, and Trump
himself.
For all the conspiracy theories and accusations that came later, that
rule was strictly applied. As far as Fusion knew, Clinton herself had no
idea who they were. To this day, no one in the company has ever met or
spoken to her.
“Okay, what do you guys got?” Elias said, turning the conversation
back to the substance of the case. “Plenty’ Simpson replied.
Fritsch and Simpson ran through some highlights of Fusion’s Trump
58 j CRIME IN PROGRESS
public record research thus far: the Trump University scam, his history
of not paying his debts, his hypocrisy on immigration, and the mount
ing evidence that he was lying about his wealth. The most perplexing
element of the work to date, they told him, was Trump’s intense and
long-lasting fascination with Russia—and his failure to consummate
any meaningful deal there. His business world intersected repeatedly
with the Russian Mafia in New York, while the sudden re-emergence of
Manafort—a consultant who had remade the Kremlij?s favorite Ukrai
nian politician in Manafort’s own image—was a major red flag.
“We think you guys will really want to pay attention to the Russia
angle:’ Fritsch said. It was obvious from Elias’s reaction that the Russia
element was new to him. “Can you tell me more?” he said.
Trumps affiliations with Russians of all kinds, Simpson said, went
way back to the opening of Trump Tower in the early 1980s, when
known Russia-connected mobsters like David Bogatin began scooping
up units, often to obscure the source of criminal profits. The five luxury
condos Bogatin bought in 1984 were later seized by the feds as part of a
massive money-laundering case. This would soon emerge as a distinct
pattern, they told Elias. In project after project, from Florida to Panama
to Toronto, Russians with dubious résumés and questionable pasts
turned out in great numbers to buy Trump-branded units.
Elias was intrigued, if a bit befuddled by all the names and dates. He
wasn~t in a hurry, and his face said: Keep going. Simpson cracked open
his MacBook to walk him through some documents.
As Trump’s own financial travails grew in the late 1980s, so did his
outreach and ties to Russia. In 1987, he took an all-expenses-paid trip to
Moscow at the invitation of the Soviet ambassador to the United States.
While there, he and his then-wife, Ivana, toured several sites for a pro
posed Trump Tower. No deal seemed likely, but soon after he came back
Trump spoke of running for the White House and took out a full-page
ad in several U.S. papers arguing that the United States should stop
spending so much to defend foreign countries, foreshadowing the pro-
Russian, anti-NATO stance he would take on the campaign trail thirty
years later.
Trump tried again in 1996 to cook up a big Moscow project, Simp
son and Fritsch told Elias, this time with the help of Howard Lorber, one
of Trump’s only true friends and a broker for wealthy Russians seeking
real estate investments in the United States. That project, too, fell flat.
The Trumps kept trying to kindle something, making repeated trips to
Moscow to view potential sites or talk to possible partners.
NEW CLIENT I 59
While Trump hadn’t succeeded in investing in Russia, they said, the

Russians had definitely begun making an investment in Trump. Many
had troubling backgrounds, and they highlighted the criminal record of
Felix Sater and Trump’s history of lying about their relationship. By
2008, Donald Trump Jr. was boasting that Russians “make up a pretty
disproportionate cross-section of a lot of our assets?’ Five years later, in
Moscow for the Miss Universe pageant, Trump again suggested that he
was deep into talks for a Trump skyscraper. (Only much later would
investigators uncover that his own representatives were trying to cook
up a Trump project in Moscow even as he campaigned to be president.)
In other words, Fritsch and Simpson stated what seemed obvious:
The party of Ronald Reagan, whose antipathy to the Soviet Union had
helped precipitate its collapse, might have real qualms about a nominee
with such close ties to the remnants of what Reagan had called the Evil
Empire.
This angle was all new to Elias, and he loved it. The research book the
DNC had put together on Trump, he said, contained none of this stuff.
Fusion’s research team would soon be hired and given wide latitude to
go where the story led it.
Formalizing the engagement with Perkins Coie, Elias’s firm, would take
weeks.
The biggest sticking point was the matter of indemnification. In
2013, Fusion had been drawn into a defamation lawsuit against Mother
Jones by a rich Romney donor and campaign finance official who had
concluded—wrongly—that Fusion was behind an unflattering article
about him published the previous year. Mother Jones eventually won
that suit, but Fusion had to defend against a third-party subpoena that
sought to expose its client and its work. That had cost the company tens
of thousands of dollars in legal fees—costs its client declined to covet If
something like that happened again, Fusion wanted to know it wouldn’t
again be stuck with the legal fees. Trump was famously litigious, and the
last thing Fusion wanted was a legal fight with a vindictive tabloid figure
with a long history of aggressive litigation.
The potential for an ugly, public fight is one big reason most private
consultants like Fusion eschew political work. (A pay scale below that of
commercial work is the other.) In a political battle with high stakes,
there is a huge incentive to attack the credibility of anyone bearing bad
tidings about a candidate or elected official, however well substantiated.
60 CRIME IN PROGRESS
In the end, Perkins Coie would not guarantee to cover Fusion’s costs
in a legal fight. That realization was the point when Fusion might have
said to Elias: Thanks, but no thanks. Fusion’s partners, in fact, discussed
bailing on the project but eventually decided the risk was worth it. The
Trump project was just too important and interesting a research subject.
The costliest component of the work, they told Elias, would be some
on-the-ground reporting they envisioned doing outside the United
States. They ran through Trump~s many trouble-plagued projects in de
veloping countries and business dealings abroad; the budget would need
to include funding for foreign investigators in Mexico and other coun
tries. The riskiest bit of fieldwork, which they didn’t yet share with Elias,
would be in Russia. They knew just the guy for the job: a Russian
speaking former spy. They figured they could do that work discreetly.
No one would ever find out about it.
CALLING AGENT STEELE I 77
bungled some bribe. Or perhaps some information that would help Fu

sion fill out the picture of Trump’s odd associations with Sater and other
criminals. Simpson later told congressional investigators: “We threw a
line in the water and Moby Dick came back:’
After reading the memo, Simpson walked a copy over to Fritsch’s of
fice and closed the door behind him. Fritsch read it, too. Once he was
finished, he looked up at Simpson, aghast. “What the hick?” he said. “I
know:’ Simpson said. They called Steele and had a brief conversation
about sourcing. They kept things vague and understated over the phone,
even on an encrypted line.
“Chris, Peter’s here with me:’ Simpson said. “We read your report.
Very interesting, to say the least. You feel pretty good about the sourcing
here?”
Steele was elliptical but firm. The sources were good: Source A was “a
senior Russian Foreign Ministry figure”; source B “a former top-level
intelligence officer still active in the Kremlin”; source C “a senior Rus
sian financial official”; source D “a close associate of Trump”; sources B
and F were inside the Ritz; and source G was “a senior Kremlin official:’
Steele offered a bit more detail on the specific placement of these
sources, which only confirmed their credibility in the Fusion partners’
minds. That was all he wanted to say over the phone.
Stylistically, the memo was typical of a field intelligence report: a
sober recitation of what sources had said, without much elaboration or
context. As with the other fifteen memos that Steele would file over the
course of the summer and fall, it didn’t purport to be flawless or 100 per
cent accurate, but it did purport to be credible, a crucial distinction. His
memoranda, like all such humint products, are designed to pass along
meaningful tips from credible sources to help flesh out or buttress other
reporting. And, equally important, they are meant for an intentionally
small audience who understands their context and purpose but also
their idiosyncrasies and limitations.
Steele and Burrows had agreed between themselves to include the
“golden showers” incident, Steele said, since it seemed to reflect a politi
cal statement about Trump’~ hatred for Obama and its availability as a
potential weapon of blackmail, not because of its salaciousness. But Bur
rows objected to Steele’s characterization of the act as “perverted:’ He
believed that was subjective and imposed a value judgment that didn’t
belong in a client report.
As an intelligence specialist, Steele was trained to filter out disinfor
Steele said that one of his collectors was among the finest he had ever
worked with, an individual known to U.S. intelligence and law enforce
ment. Neither Simpson nor Fritsch was told the name of this source, nor
the source’s precise whereabouts, but Steele shared enough about the
persont’s background and access that they believed the information they
planned to pass along was credible.*
But just because the source was credible did not mean everything the
source produced would turn out to be true. In intelligence, as journal
ism, all sources merely pass along what they see, hear, or think—not all
of which turns out to be correct. Eyewitnesses to a car accident routinely
give strikingly different versions of how it happened. That’s why news
organizations require reporters to have two sources for every key claim
in a story. But having two sources in intelligence is oftentimes a luxury.
Steele added that his team had identified a U.S.-based Russian Amer
ican in the Trump orbit. This person purported to know a good deal
about Trump’s activities in Russia and the Kremlin~s alleged support for
the Trump campaign, and was prone to talking about it with others out
side his circle. His role in the events of 2016 remains underappreciated,
even today. His name was Sergei Millian, though he has had others.
Millian had popped up in Nellie Ohr’s early reporting in November
2015 for his ties to Trump, but Fusion had yet to research him in depth.
Within days of Steele telling Fusion his name, researchers at the firm
began digging deeper into Millian, a self-promoter whose record sug
gested a background entirely consistent with that of some sort of state
intelligence asset. A linguist by training, Mfflian was the head of an ob
scure trade group with a grandiose name, the Russian American Cham
ber of Commerce in the U.S.A. He had changed his name at some point
in the 2000s from Siarhei Kukuts, around the time one of his associates
got into legal trouble. Millian was from Belarus, a small neighboring
Russian satellite state sometimes adopted as a cover for Russian opera
tives seeking to distance themselves from Russia proper.
Just two months earlier, Millian had boasted of his business ties to
Trump and extolled Trump’s virtue~ in an interview with a Russian-
government-controlled “news” outlet, ifiA Novosti, that Putin con
verted to a Kremlin propaganda outlet in 2013. The article carried a
Steele and Burrows have vowed to never reveal the source’s identity. That ano
*
nymity “is a bit of a shame, really:’ Steele later told friends. “This is a remarkable
person with a remarkable story who deserves a medal for service to the West.”
SAY SOMETHING I 83
photo of Millian and Trump along with the billionaire real estate devel
oper Jorge Perez. Dozens of other articles regurgitated the interview
across other Russian-government-controlled press outlets under head
lines such as “President Trump Is Capable of Saving Ukraine and Com
ing to Agreement with Moscow:’
Millian claimed to be working with Trump’s fixer, Michael Cohen, on
a variety of real estate projects. He displayed knowledge of other projects
as well, including bits of information that, while public, were not well
known, such as the identity of Trump’s main partner in the Trump SoHo
project. He also seemed to be familiar with the status of Trump’s real es
tate ambitions in Russia and even claimed that he had helped Trump
study the Moscow real estate market. Trump, he added, was “keeping
Moscow in his sights and is waiting for an appropriate time” to launch a
new project there. In retrospect, Millian’s cryptic statement about “keep
ing Moscow in his sights” was eerily on target. At the same time Millian
was making these comments, Trump and Cohen were in the thick of a
secret project to build a giant new tower in Moscow.
It went without saying that Steele, when he met with the FBI, would
be asked where his information came from and who had engaged him.
Fusion expected Steele to disclose the little he then knew about his
clients—that they were working for some Democrats opposed to Trump.
But he would not be able to tell them that the ultimate clients were the
Democratic National Committee and Hillary for America, because he
didn’t know that yet.
That was a big reason Fusion raised no objection to Steele going to
the FBI and felt no burning need to loop Elias in on his plans. The less
politics entered into Steele’s discussions with the FBI, the better.
Steele, like all contractors, had signed a strict nondisclosure agree
ment with Fusion. But his intel had created an exceptional situation. As
Simpson would tell Senate investigators a year later, “This was not con
sidered by me to be part of the work that we were doing.. This was
. .
like, you know, you’re driving to work and you see something happen
and you call 911:’
At the end of June, Steele reached out to Michael Gaeta, the veteran FBI
agent he had worked with to blow the whistle on corruption in the
global governing body for soccer, FIFA. Gaeta was one of the Bureau’s
most knowledgeable experts on Russian organized crime and under-
stood the nexus between the Kremlin and the Mafia. He had even had
some tangential dealings with Trump’s world; for years, he had pursued
a notorious Russian gangster known as Taiwanchik who ran his opera
tions out of Trump Tower in New York, It was Gaeta’s pursuit of Taiwan
chilc that first led him to Steele in 2010. Gaeta was now working at the
U.S. embassy in Rome as the Bureau’s legal attaché to the Italian police
and security services.
Gaeta showed up in London on Tuesday, July 5. In a meeting with
Steele and Burrows at the Orbis offices, near Victoria Station, Steele
briefed Gaeta on both his findings and sources for his early reporting to
Fusion. Gaeta reacted much the way Simpson and Fritsch had—
“flabbergasted:’ as Steele later put k—and remarked that such mailers
were far above his pay grade. He thanked them for the information and
said he would pass word up the ladder.
Steele told Simpson that he gave the information to a contact at the
FBI, whom he didn~t identifr
Neither Fusion nor Orbis knew exactly what Gaeta did with Steele’s
information, but James Comey later revealed that the FBI had in fact
opened an investigation into the Trump campaign’s possible coordina
tion with Russia a few weeks lateL As k happened, Steele met with
Gaeta the day Director Comey announced an end to the FBI’s Clinton
email inquiry, declining to charge her but saying her conduct had been
“extremely careless”—an unusual rebuke of a politician from an FBI
director.
Unbeknownst to Steele or Fusion, the FBI was also getting word of
possible Russian coordination with the Trump campaign from a sepa
rate track. In the wake of the hacking revelations, Australiis then-top
diplomat in the U.K., Alexander Downer, reported to his own govern
ment a May 2016 meeting h&d had with Trump campaign foreign policy
adviser George Papadopoulos in which Papadopoulos claimed Russia
had compromising information on Clinton. After tense internal discus
sions about how to proceed, the Australians decided to share that infor
mation with U.S. investigators. The FBI then flew two agents to London
to get the details of the conversation from DowneL This meeting, un
known to the outside world at the time, would later become another ele
ment in the bitter partisan feud over the origins of the FBI’s inquiry into
Russian meddling in the 2016 election. Republicans would come to in
sist k was Steele’s dossier, which they saw as a political hit piece, that
sparked the inquiry, while Democrats (and the FBI) asserted that the
CHAPTER NINE
HAIL MARY TIME
THE STEADY STREAM OF FRESH RUSSIA INTELLIGENCE FROM

Steele’s sources fed his growing anxiety On September 14, he sent Fu
sion another report, his seventh, and one that would prove to be among
his most prescient. “Russians do have further ‘kompromat’ on CLIN
TON (e-mails) and considering disseminating it after Duma [legislative
elections] in late September’ he wrote. The stolen emails would be re
leased through “plausibly deniable” channels, he added. Channels like
WikiLeaks.
That same day, it would later emerge, Russian military intelligence
officers posing as tipsters began contacting American reporters over
Twitter to give them passwords to protected sections of the DCLeaks
website that housed hacked DNC information. The next day, the Rus
sians reached out to WikiLeaks to begin arranging the transfer of yet
another huge cache of emails. The emails had been stolen by the Rus
sians from the personal account of Clinton campaign chairman John
Podesta.
By now, Steele had become alarmed about what he perceived to be
the FBI’s foot-dragging. He reached out to a mentor, Sir Andrew Wood,
Britain’s former ambassador to Moscow, to seek his advice and share the
intelligence he had gathered. He also messaged his contact at the State
Department, Jonathan Winer, to let him know he had developed dis
turbing information about Trump’s ties to Russia. Steele asked to meet
in person the next time he was in Washington.
In mid-September, Steele heard from the FBI’S Gaeta via Skype.
Would Steele be willing to meet with the FBI team in Rome and share
his reporting on Trump? Gaeta and Steele immediately established a se
cure system for transmission, and the reports began flowing. This sud
den flash of interest by the FBI made it clear to Steele and Fusion that the
Bureau was indeed now investigating Trump—and they had apparently
picked up something that suddenly made Steele’s memos seem a lot
more urgent and relevant. Operation Crossfire Hurricane had finally
caught up with Steele. He would go to Rome on his own dime two weeks
later.
Fusion had no way of knowing how serious the FBI probe was, and
warned Steele that it was doubtful anything dramatic would be done
before the election, thanks to long-established Justice Department rules
about refraining from any overt enforcement actions that could affect an
election in the homestretch of a campaign. Steele was always annoyed by
this explanation. Surely, he would say, national security trumps politics.
The Fusion team said nothing about the FBI’s outreach to anyone.
Simpson and Fritsch decided that if Hillary’s campaign operatives got
wind of a possible FBI investigation, it might be unable to resist the
temptation to leak it to the press. That could compromise the investiga
tion (by alerting the targets) and subject the FBI to political attacks from
Republicans that would undermine the probe’s credibility: To the Re
publicans, with their own history of misusing the government’s legal
powers to smear and punish their political opponents, that explanation
later seemed impossible to believe.
Steele was encouraged by the FBI’S outreach. Still, he was losing faith
that the Bureau would move quickly enough to put a stop to whatever
the Trump campaign and the Russians were planning.
Despite Simpson and Fritsch’s skepticism, they agreed it was impor
tant to at least try to make people aware of what was happening, even if
the truth about Trump and Russia only came out after the election.
Sooner or later, the American national security establishment was going
to have to clean up the Russia mess. And the best way to make sure the
government did its job, they thought, was to involve the media as a
watchdog.
Christopher Steele was about to break cover.
Fusion wanted Steele to come to Washington and meet the press, face
to-face. The idea of briefing the American media was a novel proposi
HAIL MARY TIME j 109
tion for Steele, who had had little contact with reporters and eyed them
skeptically. Journalists often behaved irresponsibly, he believed, and
were capable of mishandling sensitive information or selling out a
source for a good story. He had never confirmed to anyone that he had
worked for M16, even after he was outed in 1999, and he didn’t want to
start now
Trust us, Simpson and Pritsch said. There was some risk to the strat
egy; for sure, but it could be managed. They would introduce him to a
handful of reporters they knew and could trust to protect sources. All
were seasoned national security or investigative reporters who dealt
regularly with confidential whistleblowers and former intelligence and
law enforcement officials.
Steele wouldn’t have to mention M16 or name a single source, they
told him. His name and nationality will be off-limits.
“Do you think they’ll write stories based on what I say?” Steele
wanted to know.
Probably not, they said.
Much like the Justice Department’s policy against taking overt inves
tigative steps against candidates in the sixty days before an election, re
porters try to begin wrapping up their investigative work on the
presidential campaigns soon after Labor Day, to avoid the risk of being
manipulated by one side or the other into an unfair or untrue “late hit:’
The idea, Simpson told Steele, was to alert some leading journalists
in the national security community to a potential crime in progress in
the hope that they would investigate it, whether or not Trump won.
Multiple signs pointed to active cooperation between the Trump team
and Moscow At a minimum, Putint’s men were openly aiding the cam
paign in ways that violated U.S. law If the two sides weren’t working
hand in hand, then at the very least the Russians were manipulating top
aides and advisers to the Republican candidate. All of this warranted
scrutiny, even if it seemed unlikely that the story would become public
before Election Day. That shouldn’t matter: Clinton seemed almost cer
tain to win.
Steele flew to Washington on September 21.
Fritsch reserved two private rooms at 10 A.M. the next day at the Tabard
Inn, a quiet, discreet, and charmingly shabby spot a bit removed from
Washington’s power corridors. The meetings were organized in one-
hour sessions, with breaks staggered between the rooms to prevent jour
nalists from bumping into one another as they came and went. The guest
list included Jane Mayer of The New Yorker, Michael Isikoff of Yahoo
News, Matthew Mosk of ABC News, and Eric Lichtblau and David
Sanger of the Times. Later, the Fusion partners took Steele to the offices
of The Washington Post, where they met with Tom Hamburger and Dana
Priest. Collectively, these reporters boasted more than 150 years of ex
perience reporting in Washington and had won virtually every award
the news profession has to offet
Fusion laid the ground rules. Steele would speak only on back
ground, meaning any information the reporters wished to quote could
only be attributed to a “former senior Western intelligence official:’ His
name and nationality were off-limits. Fusion, they explained, had hired
Steele to look into Trump’s business dealings with Russia. But he had
developed information along the way that pointed to a more sinister
relationship, one with serious national security implications. The infor
mation was Steele’s, not Fusion’s. Yes, Fusion was working for a client
opposed to Trump. No, Fusion would not identify that client. If that
meant the reporters didn’t want to hear from Steele, no problem.
The reporters all agreed to those terms. The Steele memos that would
later come to be known as the dossier were not shown or given to any of
the reporters.
Fusion explained Steele’s background as a reliable source of intelli
gence to U.S. law enforcement and invited them to check his reputation
with their sources. Many of the reporters wanted to know if the U.S.
government was aware of what Steele had found and whether it was in
vestigating. Not wanting to compromise the FBI’s investigation, Simp
son and Fritsch kept it vague: It would be fair to assume the U.S.
government was aware of Steele’s information, they said. Only Isikoff
pressed the question aggressively, eventually squeezing out of Steele an
admission that he had briefed the FBI about Carter Page and other mat
ters.
Steele did almost all the talking. Simpson and Fritsch would interject
occasionally for context and explain how Steele’s conclusions jibed with
what was in the public record.
In the meetings, Steele ran through his key findings. He played down
the hard-to-confirm details of Trump’s alleged nocturnal exploits dur
ing the Miss Universe pageant in 2013 and emphasized his reporting on
Page’s mysterious Moscow mission and meetings with people from the
HAIL MARY TIME j 111
Kremlin and Rosneft—the fattest hog in Putin’s kieptocratic corporate

pigsty He noted that his sources had mentioned discussions between
Page and Russian officials about Trump lifting U.S. sanctions on Rus
sians in return for other favors. The sourcing there was particularly
solid.
In a New Yorker article, Jane Mayer would later describe her session
with Steele. “Despite Steele’s generally cool manner, he seemed dis
traught about the Russians’ role in the election. He did not distribute his
dossier, provided no documentary evidence, and was so careful about
guarding his sources that there was virtually no way to follow up.” May
er’s published account was faithful to her real-time reaction: Interesting,
but what is the point of this ~f none of it can be confirmed?
Isikoff decided to see what, if anything, he could run down with his
own law enforcement sources. After verifying Steele’s bona fides, he got
through to a senior law enforcement official who confirmed investiga
tive interest in Page’s supposed meetings with Sechin and other Kremlin
types. The day after his encounter with Steele, Isikoff published a story
under the headline “U.S. Intel Officials Probe Ties Between Trump Ad
viser and Kremlin:’ The story recalled Senator Reid’s blind reference to
what must have been Page in his letter to Comey and reported the al
leged Sechin meeting Steele had described. The story also mentioned
another alleged meeting Page had with a top Kremlin official, Igor Div
yekin.
Isikoff’s September 23 story made a modest splash for a day or two.
A few days later, Page told the Post that he would be taking a “leave of
absence” from the Trump campaign and trashed Isikoff’s story as “com
plete garbage:’ The core allegation of the story, that Page was being in
vestigated for allegations that he had “opened up private communications
with senior Russian officials—including talks about the possible lifting
of economic sanctions if the Republican nominee becomes president:’
was later proven to be accurate by congressional investigations.
The campaign’s swift moves to distance itself from Manafort and
Page limited the fallout and contained the story, but at least Fusion and
Steele felt satisfied that their work had helped lead to two of the Trump
campaign’s suspected intermediaries with the Russians being taken off
the field.
“The primary objective of most counterintelligence operations is
disruption, so we’re not doing badly:’ Steele pointed out.
The following month, the Foreign Intelligence Surveillance Court
approved a wiretap of Page—a fact that wouldn~t emerge until well after
the election. A highly redacted copy of the court’s order said that Page
had “established relationships with Russian government officials, in
cluding Russian intelligence officers:’ and that the FBI thought “the Rus
sian government’s efforts are being coordinated with Page and perhaps
other individuals” tied to the Trump campaign. Still later, it came out
that Russian intelligence had tried to recruit Page in 2013. The FBI had
even asked him about his Russian contacts in March 2016—the month
Trump introduced him to the editorial board of the Post as part of his
foreign policy team. And this was all long before Steele had ever heard
of Carter Page, much less put his name in a report.
Trump defenders would later try to advance the notion that the
briefings at the Tabard Inn had led to a spate of oppo-driven stories in
the final weeks of the campaign. The truth is, the story in Yahoo News
was the only one that emerged from the Steele sessions.
After making the rounds with journalists, Steele met with longtime for
mer State Department official Jonathan Winer in a Washington hotel
and gave him a rundown of the intel he’d gathered, akin to the one he
had just given reporters.
Simpson and Fritsch had known Winer for years. The lawyer and
diplomat knew a lot of journalists in town, dating back to his days as an
Iran-contra investigator for Senator John Kerry. He was a specialist in
money laundering and transnational crime. After leaving government
in 1999 for private consulting, he developed a specialty in the countries
of the former Soviet Union. He met Steele soon after Orbis was founded
in 2009.
Winer returned to government in 2013 at then—Secretary of State
Kerry’~ request as special envoy for Libya. On the side, he acted as an
informal pipeline between Steele and State Department official Victoria
Nuland for Orbis’~ reporting on Russia. Again, Steele shared that work
for free, in the interest of helping an ally augment its understanding of a
place where good source intelligence was hard to come by, increasingly
so since the shift in the Intelligence Community’s focus to Islamic terror
after 9/11.
Winer was stunned by Steele’s Trump findings and vowed to do what
he could to bring the matter to Secretary Kerry’s attention. As a lawyer
and veteran of many D.C. political scrapes, Winer was also sensitive to
HAIL MARY TIME I 113
the optics of the situation: Here was a former British spy working for
some former journalists who, he knew, were probably working for the
Democrats.
Soon after his meeting with Steele, Winer called Fritsch and asked to
talk. Winer and Fritsch live in the same neighborhood in the Washing
ton suburbs. One evening in late September, Fritsch went to Winer’s
house with a copy of all the reports Steele had produced to date. Fritsch
allowed Winer to read them and take notes, for the express purpose of
making Kerry aware of the substance of Steele’s reporting.
Winer then pulled out a document of his own for Fritsch to review.
It was a report that appeared to be written by some kind of investigator,
but it was sioppy and unformatted; it looked like a reporter’s raw notes.
Its findings, however, were explosive: They echoed Steele’s own report
ing that the Russian FSB spy service had tapes of Trump having sex with
prostitutes in Moscow. It was now Fritsch’s turn to be stunned.
This appeared to be a totally different reporting stream, providing a
measure of corroboration for Steele’s reporting. But was this report le
gitimate? It made reference to conversations with journalists, including
the Journal’s former Moscow correspondent Alan Cullison. Was this all
just hearsay or reporter gossip? There was no way to know. Winer would
only say that it came from a trusted friend. Fritsch had a few suspicions
about who that was. Winer had long been friends with Sidney Blumen
thal, a former journalist who had gone on to work in the Clinton White
House and become very close to both Bill and Hillary. Fusion knew that
Blumenthal worked with a Los Angeles—based freelance journalist
named Cody Shearer to generate opposition research for the Clintons.
Fritsch asked if his hunch was right, but Winer would neither confirm
nor deny.
When Fritsch returned to the office and described the document to
his colleagues, Simpson sighed and said, “We don’t want to get within a
thousand miles of that:’ But the parallels to the dossier were admittedly
intriguing. Fusion’s suspicions later proved correct. Shearer was, in fact,
the author of the document, and Blumenthal had indeed passed it to
Winer, who also shared a copy with Steele.
Steele had no idea who Blumenthal was and had trouble accepting
Fusion’s warnings to him that anything the Clinton operative touched,
no matter how legitimate, was destined to be branded as hopelessly par
tisan. Winer had explained to Steele the origin and chain of custody of
the document. Even still, Steele believed the parallels to his own report-
Steele and the Fusion partners exchanged a flurry of calls over the week
end and entertained a variety of options, including bringing Steele back
to the United States to speak publicly about his findings and dealings
with the FBI. Perhaps a press conference on the steps of the Capitol?
That was quickly ruled out as too silly and likely to backfire.
No, the best route was to find a reporter who trusted Fusion and who
just might have the aggressiveness to write a story this explosive in the
final days of a presidential campaign. David Corn, the Washington cor
respondent for Mother Jones, fit the bill. He was an old acquaintance of
Simpson’s and occasionally reached out to him for news leads.
After the Comey letter was released, it occurred to Simpson that
Corn was an espionage buff who’d written a well-researched biography
of a notorious former CIA official. He would be capable of evaluating
Steele and his information much more quickly than a typical political
reporter. Simpson texted him and suggested they meet.
That weekend, Corn and Simpson met at the Pain Quotidien off Du
pont Circle. Simpson described the contents of the dossier and then,
when they were done eating, walked Corn back to the Fusion office and,
later, let him review a copy. “This is crazy stuff:’ said Corn. “But how am
I supposed to know if any of it is true?” Simpson explained that it had
come from MI6’s former lead Russianist. Corn lobbied to speak with the
author as soon as possible.
The next day, October 31, Simpson arranged a three-way Skype con
versation with Steele and Corn, something Steele was reluctant to do.
The ground rules were the same: You could quote him as a former senior
intelligence official, but you could not identify Steele’s name or national
ity: In short order, Corn satisfied himself that Steele was the real thing
and that the authorities were indeed taking his information seriously.
Hours later, Corn went online with his story: “A Veteran Spy Has Given
the FBI Information Alleging a Russian Operation to Cultivate Donald
Trump:’
That story would cause the FBI to cut Steele loose as a source. Gaeta
called Steele after the story ran, and the two exchanged sharp words.
Steele said he had been led to believe the story wouldn’t be explicit about
his relationship with the FBI, adding angrily that “any misstep by Orbis
or Fusion pales in comparison to what Comey did in disclosing the Hil
lary investigation:’
Referring to Steele by the acronym CHS (confidential human source),
the FBI typed up a form FD-lO4Oa, titled “SOURCE CLOSING COM
MUNICATION:’ Steele had “confirmed to an outside third party” that
HAIL MARY TIME I 119
he had a confidential relationship with the FBI. That relationship now

appeared to be over.
At this point, Steele diddt really care. Nor did Fusion. Comey had
demonstrated bad faith in publicly reviving the FBI’s investigation of the
Clinton email server while burying an investigation of Russia’s attempts
to compromise a presidential candidate. “The public absolutely needs to
be made aware of this information:’ Steele said.
Cords story caused a minor stir, which was disappointing but not
terribly surprising. Another potentially impactful story was posted by
Slate barely a half hour later, at 5:36 P.M., written by Washington jour
nalist Franklin Foer.
Foer recounted the efforts of some of the country’s most renowned
computer scientists to analyze Internet traffic they’d stumbled on linking
a computer server sifting in Trump Tower with a politically connected
bank in Moscow. The headline, “Was a Trump Server Communicating
with Russia?:’ was a bit equivocal, but the facts were intriguing, at the
least. According to Slate, the servers appeared to be specially configured
to communicate with each other, the equivalent of a hotline.
The institution in question, Alfa Bank, was known to Fusion. Its
owners were billionaire oligarchs close to Putin. One owner, Petr Aven,
would later testify to special counsel Robert Mueller that he “met on a
quarterly basis with Putin, including. shortly after the U.S. presiden
. .
tial election:’ Aven made clear that he took his orders from the Kremlin:
As the Mueller report later stated, “Aven said that he took these meet
ings seriously and understood that any suggestions or critiques that
Putin made during these meetings were implicit directives, and that
there would be consequences for Aven if he did not follow through.”*
Foer’s story lit up Twitter. It was a complicated but deeply reported
tale with authoritative sourcing. At a minimum, it called for further in
vestigation. The Clinton campaign jumped on it instantly, taking to
Twitter. They had hoped the big boys would follow up and rebalance the
scales, post-Comey.
Fritsch knew the story would cause heartburn for other reporters in
town, particularly at the Times and the Post. Both publications had been
chasing the Alfa story, but Fusion had heard that senior editors had
* Another Alfa owner, German Khan, is the father-in-law of Alex van der
Zwaan, a former Skadden Arps lawyer who pleaded guilty to lying to Mueller. Mar
shall Cohen, “Dutch Lawyer Who Pleaded Guilty in Mueller Probe Serving Sen
tence in Pennsylvania,~’ CNN Politics, May 9, 2018.
“COURAGE, FOLKS” I 125
year and what we want to do next:’ Fritsch wrote. “We are going to need
a real budget from a solid group of donors who really love this country:’
The early responses were encouraging.
Simpson and Fritsch felt certain there was an active FBI investiga
tion of the president-elect and thought they had a responsibility to now
go beyond the steps they had taken before the election. The national
security community and the public needed to understand their con
cerns about Trump~s possible compromise.
That’s where Steele’ä mind was, too.
In its seven-year history, Orbis had twice stepped outside its role as
private consultants to warn the government of a potential national secu
rity emergency. In 2014, it went to the German government with credi
ble information indicating that ISIS was planting operatives among
Syrian refugees headed to Western Europe. In 2015, Steele and Burrows
helped a former M16 officer in China make a discreet report to the U.K.
government about an attempt by Chinese intelligence to recruit him.
During the 2016 campaign, they decided to hold off on reporting
their concerns about Trump and the Russians to the U.K. authorities.
“The FBI was against our doing that:’ Steele recalled. “We made the crit
ical decision not to go to the U.K. government unless Trump was
elected:’
Steele and Burrows believed, however, that Trump’s election had
profound implications for U.K. security and decided to alert British au
thorities. On November 15, Steele went to the Wimbledon home of Sir
Charles Blandford Farr, chairman of the Joint Intelligence Committee, a
cabinet-level position roughly equivalent to director of national intelli
gence in the United States. Farr was himself a former spy who had served
M16 in Afghanistan in the 1980s and was friendly with Steele and Bur
rows. Steele gave Farr a summary of their findings.
“He took our reporting extremely seriously:’ Steele recalled. After
the meeting, Farr wrote an executive summary of the reporting that, he
told Steele, went in early December to Andrew Parker, head of M15,
Britain’s domestic security and counterintelligence agency, and to the
wider cabinet.
In Steele’s view, the U.K. government eventually concluded that the
contents of the dossier constituted as much a political problem as a
counterintelligence issue. The United States is Londont’s closest ally. The
two countries stand together on nearly every issue of international sig
nificance. There was little chance the electoral outcome woui.d be re
and that the information came from Steele, a highly credible source.
This was information McCain needed to hear right away, Kramer con
cluded. Later that afternoon, he and Wood briefed the senator in a small
breakout room used for private meetings. Wood mentioned the possi
bility of a video showing the president-elect in a compromising situa
tion in a Moscow hotel suite. “The senator listened very carefully. He
didn’t really have much in the way of a reaction:’ Kramer said. McCain
then “turned to me and asked me if I would go to London to meet what
turned out to be Mr. Steele”
McCain recalled the encounter in his book The Restless Wave: “Our
impromptu meeting felt charged with a strange intensity. No one wise
cracked to lighten the mood. We spoke in lowered voices. The room was
dimly lit, and the atmosphere was eerie:’ Reassured by Wood that Steele
was reliable, McCain concluded that “even a remote risk that the Presi
dent of the United States might be vulnerable to Russian extortion had
to be investigated:’
Fusion didnt’t learn of this meeting until days after it occurred.
The Sunday after Thanksgiving, Kramer took an overnight flight
from Washington to London, using his own frequent-flier miles. He
gave Wood his cellphone number and boarded the flight, knowing only
that he would be met upon his arrival at Heathrow. Once on the ground,
he received a text message from Steele instructing him to look for a man
in a blue ~coat holding a copy of the Financial Times (a bit hokey, per
haps, but sometimes life imitates pulp fiction). Kramer located Steele
outside customs. Steele then drove Kramer to his home in Farnham,
about thirty miles southwest of Heathrow.
Once they had settled in the living room, Steele handed Kramer the
memos Orbis had produced to date and explained that they were field
intelligence collected for a private client he did not name. The sources
had proven extremely reliable in the past, and their information had
checked out. “He explained again that the information he gathered was
what he found, not what he thought the client might want:’ Kramer later
said. “He stressed that point to me several times:’
Steele explained his sourcing and provided Kramer with sufficient
background information to explain how each person was in a position
to know what they knew. Simpson and Fritsch had been similarly briefed
during the election; the detail about the quality of the sources signifi
cantly increased the credibility of the reporting in their minds. Steele
declined to give Kramer a copy of the memos; he worried that Kramer
might be searched upon reentering the United States. He also hadn’t had
a chance to confer with Fusion.
Steele told Kramer that he had shared his information with the FBI
but that the relationship had soured, and that he understood Kramer
might be in a position to get his reports to Senator McCain for the ex
press purpose of asking FBI Director Comey what was going on. Kramer
said that, yes, he represented McCain in an unofficial capacity and he
believed he could do that.
After they walked through the memos, Steele took Kramer to lunch
and then back to Heathrow for a 4:20 P.M. United flight back to Wash
ington. Steele said that, once Kramer was back in the United States, he
could get him a copy of the reports from Simpson, who Steele said had
hired him. Kramer had spent a total of about eight hours in the U.K.
Once Kramer was airborne, Steele checked in with Simpson and told
him of his hastily arranged rendezvous with Kramer. Was Kramer as
close to McCain as he claimed, and could he be trusted with a copy of
the dossier? Steele asked.
“Yes:’ Simpson replied. “I’ve known David for a long time. . He’s
. .
legit’ He recounted the role Kramer had played as a confidential source

for Wall Street Journal stories in 2007 and 2008 outing Oleg Deripaska’s
visa problems and his Washington lobbying activities.
“David loathes Putin and his oligarchs with a passion:’ Simpson told
Steele. “I’m not really sure what accounts for the virulence of his ani
mosity; but it might be because he saw disturbing classified information
about Deripaska and Putin when he was at State. In any event, we defi
nitely do not need to worry about where he stands on the Russians.”
Steele asked Simpson to provide a copy of the Steele memos to
Kramer so that he could pass them along to McCain, who Kramer said
had promised to raise them directly in a private meeting with Comey.
Simpson agreed.
The next day, November 29, Kramer made his way to the Fusion office
in Dupont Circle for a 5 P.M. meeting with Simpson. Fritsch was out of
town, so Simpson asked Berkowitz to join.
It had already turned into another hair-raising day. That morning,
Orbis sent over a fresh memo (it was continuing its work pro bono) re
lating some chatter out of Moscow concerning Trump’s recruitment of
Mitt Romney to be his secretary of state. The choice struck many as odd,
The Fusion team figured Bensinger might be in a position to tell

them how deeply the FBI had relied on Steele in the FIFA case, some
thing Steele himself diddt want to discuss. Simpson thought that, de
pending on how close Bensinger was to Gaeta, he might have an outside
shot at confirming the active investigation of the president-elect’s Russia
entanglements.
By the time Bensinger got to the house it was late, and the rest of the
Fusion team soon rolled off to bed. Simpson and Bensinger stayed up,
and Simpson described—off the record and in general terms—the con
tents of Steele’s reports and Fusion’s relationship with the former spy.
Simpson didn’t show or give Bensinger any of Steele’s reports but sug
gested that he reach out to Steele directly, given their prior contact on
the FIFA story.
Bensinger had an early flight back home to L.A. the next morning.
He was gone before any of his hosts arose, armed with a good lead and a
source in London he knew to be highly reliable.
The next day, Steele was sitting with Burrows in London’s Garrick Club,
an ornate gentlemen’s retreat whose past members include Charles
Dickens, H. G. Wells, and Sir Laurence Olivier. They were there to brief
their old boss, Sir Richard Dearlove, former chief of MI6. Dearlove was
a legendary spy, who had served in Prague and Nairobi and ran the
Washington, D.C., station before rising to run the agency from 1999 to
2004. Steele and Burrows desperately wanted to escalate their findings,
and Dearlove, knighted by Queen Elizabeth in 2001, would be the man
to do it.
They pulled out a copy of the dossier and the spy chief read it care
fully. They walked him through some of the sourcing, in the most gen
eral terms. The reporting was credible, Dearlove said. He then surprised
Steele and Burrows by indicating that he was already aware that the Brit
ish government had suspicions about links between Russia and mem
bers of the Trump campaign. It seemed the British government had
made a political decision to not push the matter furthet
This news irritated Steele while at the same time reinforcing his view
that his reporting was strong. If MI6 had reason to believe that the in
coming head of state of Britain’s top ally could, in fact, be compromised
by Moscow, he asked himself, why would the government be willing to
“kick it into the long grass?”
“I NEED TO KNOW IF ANY OF THIS IS TRUE” I 141
Times reporters through Trump’s business entanglements with Russia

and the elements of the dossier. They also walked through Fusion~s role
in the research. They stopped short of identifying their two anti-Trump
clients, other than giving some generalities that Simpson and Fritsch
had previously agreed upon: In the beginning, there was a Republican.
Then, there was a Democrat.
As the meeting wound to a close, Mazzetti asked if they might have
a copy of the Steele reports, on a strictly off-the-record basis. It was not
to be reprinted, shared, or published. The Fusion partners hadn’t checked
with Orbis, but they agreed and passed them across the table.
Little did the two Fusion partners know, but thanks to David Kramer,
awareness of the dossier around Washington was spreading—far be
yond the confines of the discreet confidential encounters they’d had
with the Times.
At McCain’s behest, Kramer briefed the dossier’s contents to a pair of
Obama administration Russia hawks: Celeste Wallander, senior director
for Russian affairs at the National Security Council, and Victoria Nu
land, assistant secretary of state for Europe and Eurasian affairs. Both,
Kramer later said, knew of Steele and believed his work to be credible.
But Simpson and Fritsch had never met or talked with either of them—
and Kramer never asked them to.
By the turn of the year, Kramer had also given copies of the dossier
to a Republican congressman from Illinois whom Kramer knew and to
a top aide to Speaker Paul Ryan.
All that would become known only later. At the time, Fusion had no
inkling of what Kramer was doing and would have objected strongly
had they known. The deal they had made with Kramer was a simple one:
He could have Steele’s memos for the express purpose of giving them to
McCain so that he could share with Comey. Period.
As the inauguration of Trump drew closer, Kramer’s evangelizing for
the Steele memoranda grew ever more frenzied and would take a fateful
turn when BuzzFeed reporter Ken Bensinger reentered the picture
shortly after Christmas.
Bensinger, who was based in Los Angeles, was a resourceful and en
ergetic reporter eager to follow up on Simpson’~ tips from their Califor
nia conversation in hopes of netting a juicy scoop for his FIFA book, at
a minimum. He had previously arranged to meet with Steele in London
on January 24 to do more reporting on his book. But Bensinger now

knew about Steele’s reports and had grown worried that Steele might be
less willing to talk by that date, which was four days after Trump was
scheduled to be inaugurated.
Bensinger texted Steele on December 23 to say that something had
come up and he now wanted to come earlieL Steele asked what was so
urgent—couldn’t it wait until after the holidays? The next day, Bensinger
texted that “people” were telling him about a dossier describing how
Trump had been compromised by the Kremlin.
“Can we discuss?” he asked.
Steele, who knew nothing of Fusion’s chance encounter with Ben-
singer in Sonoma, didn’t reply.
On December 29, Bensinger hopped on a flight from L.A. to Wash

ington.
Soon thereafter, Steele got a text message from Kramer saying he had
spoken to Bensinger and given him “the broad picture:’ Kramer later
claimed he’d done so at Steele’s urging; Steele disputes that.
In any event, Bensinger was now hot on the trail of the dossier, push
ing all his sources—none more so than Simpson, whom Bensinger im
plored to give him a copy of the rumored memoranda. Failing that,
could he at least show him a copy? Simpson declined. He was not going
to provide such sensitive written material to a reporter he barely knew.
Undeterred, Bensinger went to meet Kramer. He had learned from
an unknown source—not Fusion and not Orbis—that Kramer had a
copy of the Steele memos and arranged to meet with him. The two met
at the McCain Institute’s deserted offices near the State Department in
Foggy Bottom. The offices were closed for the week, but Kramer was
there and had the dossier sitting on a table in front of him. Russia was
still very much in the news. Indeed, that very same day, President Barack
Obama had expelled thirty-five Russian diplomats and announced other
measures in retaliation for Russia’s hack attacks and election interfer
ence.
How exactly Bensinger obtained page-by-page photos of the high
lighted dossier from Kramer was later the subject of some dispute.
Kramer initially claimed he had not known that Bensinger would pho
tograph the documents. “He said he wanted to read them, he asked me
if I could take photos of them:’ Kramer testified in a defamation case. “I
“I NEED TO KNOW IF ANY OP THIS IS TRUE” I 143
asked him not to. He said he was a slow reader, he wanted to read it. And
so I said, you know, I got a phone call to make and I had to go to the
bathroom. and so I left him to read for 20, 30 minutes:’
. .
Bensinger photographed the dossier with his iPhone.

In journalism and politics, the old “I left the room for twenty min
utes” is a familiar ruse by sources who want plausible deniability for
sharing confidential information. Kramer had been a senior govern
ment official who was accustomed to speaking to the media under a
cloak of anonymity; he had done so with Simpson himself a decade ear
lier. Kramer likely knew exactly what he was doing—despite the explicit
conditions he’d agreed to with Simpson that the memos were for Senator
McCain and no one else.
Indeed, Kramer later admitted to having given a copy of the memo
randa to two reporters for McClatchy newspapers in early December
2016 and eventually to at least four other news organizations.
Bensinger later testified that Kramer had explicitly allowed him to
photograph the dossier with his iPhone. Kramer was forced to clarify for
the record and say that he “had no objection’ to Bensinger taking the
report with him.
Bensinger had dinner that night with Simpson at a trendy farm-to-
table restaurant on Connecticut Avenue called Buck’s Fishing & Camp
ing. Over dinner, Bensinger informed Simpson that he would no longer
need to pester him for a look at the Steele memos. He said he had taken
care of that with a new source—someone in Foggy Bottom. Simpson
assumed that Kramer had simply briefed Bensinger on the contents and
that Bensinger had left satisfied.
On New Year’s Eve, Simpson flew to Mexico on vacation. That same
day, Bensinger texted Steele asking if he was available to meet in London
on January 3. Based on Bensinger’s Christmas Eve text, Steele was con
cerned that he would want to talk about the Trump investigation, but he
took the meeting based on Bensinger’s claim that he wanted to discuss
FIFA.
Ever the intelligence officer, he also wanted to find out what Ben-
singer had learned in Washington. At their meeting, Bensinger gave no
hint that he had a copy of the dossier. When Bensinger turned the con
versation to the substance of the Trump reports, Steele grew more
guarded, and Bensinger left soon after.
Unbeknownst to Fusion or Steele, by then the Steele memos were all
over town, thanks to Kramer. The Wall Street Journal had a copy. So did
tle shop above a Starbucks and a consignment store had kept such a low
profile, it barely warranted a page of mentions on Google. Its deliber
ately barebones company website featured little more than a one-
paragraph statement of purpose and an email address, which fed an
inbox that was largely empty;
Within hours, that comfortable sense of anonymity went up in a puff
of headlines and cable hits as the people behind the dossier became
known. First to fall was the shroud around Steele.
In London, Wall Street Journal reporter Alan Cullison began calling
Steele’s friends and workmates. Kramer had given Cullison a copy of the
memos in December. Now Cullison was reaching out directly to Steele,
who told him he’d be willing to talk one day but that at the moment it
was “too hot:’ Circumstances had now changed: The Journal seemed
intent on outing Steele as the dossier’s author.
Orbis and Fusion grew concerned that the media frenzy over the
memos would cause outlets to override previous promises of confiden
tiality; raising possible safety concerns for staff. That became a near cer
tainty on January 10 when a young reporter for the Journal showed up
at the home of Steele’~ business partner, Chris Burrows, some seventy
miles southwest of London and explained that he’d just traveled about
ninety minutes on the U.K’s notoriously shoddy South West service.
“You poor sod, you’ve been on South West Trains!” Burrows said
cheerily. “You’d better come in:’ As they stood in his kitchen, the re
porter explained his mission and brandished a copy of the Steele memos.
“Is this yours?” he asked. Burrows said he could neither confirm nor
deny, sent the reporter packing, and immediately phoned Steele.
Steele suspected that Kramer was the leak and phoned him to try to
figure out what was happening. Kramer denied he had leaked but volun
teered to try to convince the Journal to protect Steele’~ identity. “They
had already made up their mind, it was clear to me, although I spent a
good hour or two talking to them, explaining why this was a terrible
decision on their part:’ Kramer later recalled.
The story went up on the Journal’s webpage that evening. Steele had
already taken his family and fled his house, so by 10 P.M., British tabloid
journalists were outside the Burrows house. By the following morning,
the TV trucks were there. There was also a large media scrum camped
outside the Orbis office in London, near Victoria Station.
The British government swiffly issued a so-called DSMA-Notice—an
informal, voluntary request asking newspaper editors to refrain from
“YOU ARE GONNA GET PEOPLE KILLED” I 149
publishing information that would be harmful to national security “The

public disclosure” of Steele’s name “would put the personal security of
that individual directly at risk:’ read the statement by secretary of the
Defense and Security Media Advisory Committee. It was a noble but
futile gesture.
A few of the reporters who played a role in exposing Steele would
later express regrets about the personal consequences for Steele. Among
the first was BuzzFeed’s Bensinger.
“I am sorry this has been a difficult week:’ he texted Steele after the
Journal story. “I was very upset to hear you were forced to go into hid
ing. For what it is worth, which I suspect is not much, I have not told
anyone we met and do not plan to, and have not mentioned your name
to anyone.”
For weeks and from his various hiding places, Steele would phone
Simpson and Fritsch around 11 or 12 at night in the U.K., which was the
end of the working day in Washington and around the time the cable
news networks began giving their wrap-ups of the latest developments.
In a hushed and often strained voice, Steele would provide vague ac
counts of his whereabouts and ask for a read on what was likely to hap
pen next—always with an eye toward whether his sources might be
exposed in the coming investigations. The Fusion partners would do
their best to hold his hand while explaining how hard it is under the U.S.
legal system to keep even sensitive information under wraps. “You can
expect for every detail of our work together to become known, sooner
or later:’ Fritsch told him one night.
“Utterly outrageous that a government can’t keep its secrets:’ Steele
replied.
Next to be exposed was the firm that hired Steele.
In Washington, Simpson received a call from Times reporter Scott
Shane, who said he was reporting on the origin of the Steele memos and
wanted to review the history confidentially Simpson walked him
through some of the basics. Simpson then mentioned that he’d heard the
website Gizmodo, at that very moment, was attempting to out Fusion as
the firm that had commissioned the Steele memos. Then why not go on
the record with me? Shane asked. Simpson declined, reminding Shane
that the paper had agreed to keep Fusiont’s identity under wraps.
As the media frenzy reached a crescendo that night, Simpson grew
concerned that Shane might not keep that deal. So he called a Times
editor he knew in New York. “I have a feeling you’re getting ready to out
us,” he said, protesting that such a move would be improper, since Fu

sion had honored its end of the confidential source agreement.
You should be outing your government sources instead, Simpson
argued—the ones who, it now seemed clear, had deliberately misled the
paper the previous October about the seriousness of the FBI’s Trump-
Russia investigation. The editor gave no promises on Fusion’s fate, but
readers, he said, hadn’t seen the last of the October episode.
At 9:17 that night, the Times’s story hit the Web: “How a Sensational,
Unverified Dossier Became a Crisis for Donald Trump.” It identified Fu
sion as the firm that had hired Steele, and described it as a firm “some
times hired by candidates, party organizations or donors to do political
‘oppo’ work:’
Fritsch and Simpson were furious. The Times had used information
about Fusion it had learned off the record and put it on the record uni
laterally. Fritsch fired off a couple of angry emails to Times reporters
that he instantly regretted. The truth was that Fusion’s identity was
bound to come out—and the Times story wasn’t unfair. The heated re
action was fueled as much by an anticipatory dread of what Fusion
feared could happen next: angry attacks from Trump supporters; ner
vous clients wanting to ditch Fusion; retribution from the incoming
administration.
“We are in for some serious shit now:’ Fritsch told Catan that night.
Simpson locked himself in a spare bedroom and watched as his
phone vibrated every few minutes with another message—a TV station
in Japan, an old college friend, a Trump supportet Scenarios for what
might happen next played out in his head. One thing was for sure: Fu
sion would come under investigation by the Republican-controlled
Congress, which had already vowed to look into the Russian attack on
the election. The moment reminded Simpson of how he had felt after
the death of a close friend in a plane crash: Something awful had sud
denly happened, but there was nothing to do about it.
The next day, the main topic of conversation in the Simpson and
Fritsch households was security. Simpson’s house was less than a mile
from Comet Ping Pong, the local pizzeria that had been shot up three
weeks earlier by a Trump supporter who was convinced the restaurant
was operating a child sex abuse dungeon tied to the Clintons. Simpson
and his wife began to discuss whether their home was safe and decided
to spend thousands of dollars to replace their flimsy backyard fence with
a stout wooden wall seven feet high.
CHAPTER SEVENTEEN
“WHAT I’M GOING

TO DO TO YOU
FIGHTING BACK FELT GOOD, VERY GOOD.

The Times op-ed triggered a large wave of positive media coverage—
as well as limp denials and denunciations from Republicans. “Hero-
grams have temporarily replaced threats” in messages landing in Fusion’s
general email account, Catan told the partners.
The uplift was short-lived.
Two days later, a federal judge rejected Fusion’s effort to block the
House Intelligence Committee from obtaining more of its bank rec
ords. “Federal Judge Obliterates Fusion GPS’ Attempt to Hide Info
from Investigators’ screamed one right-wing website. The next day,
Grassley and his new wingman, Lindsey Graham, launched a counter
offensive against Fusion and Orbis, announcing they’d sent a letter to
the Justice Department demanding a criminal investigation of Chris
topher Steele for supposedly lying to the FBI. The FBI was fully ca
pable of referring for criminal prosecution any individual it believed
had knowingly lied to or misled them. That had not happened. The
Graham-Grassley referral was a transparent political stunt. On Fri
day, TD Bank dispatched a copy of Fusion’s account records to the
House.
It made for a lousy, wintry weekend. Of all the accusations leveled
against Orbis and Fusion in the year since the dossier became public, the
accusation by Grassley and Graham against Steele was perhaps the most
outrageous. Steele phoned Simpson and Fritsch, distraught by these de
velopments.
“WHAT I’M GOING TO DO TO YOU...” 231
“I have served my country loyally for twenty years and only did what
I thought was right:’ he told Simpson. “This is how I am thanked? These
people have no shame;”
Fritsch and Simpson spent the weekend reassuring Steele and Bur
rows that this was just politics. The Justice Department and the FBI
would be hard-pressed to pursue a criminal case against someone out
side of the country, let alone a British citizen who’d helped them repeat-
eddy and honestly. “At least I hope that’s still the case:’ Simpson told
Fritsch privately.
Fritsch’s and Simpson’s words were small consolation to Steele. The
Grassley accusation was all over the U.K. press, and Steele thought no
one there would appreciate the political context of it—especially since
Grassley had lobbed the charge for maximum publicity while refusing
to make public any specifics. Wbat was it that Steele had lied about?
Grassley wouldn~t say.
The unhappiness only deepened the following week when The New
York Times published a less-than-flattering proffle of Simpson, describ
ing him as “brash, obsessive, occasionally paranoid, perhaps with cause:’
That’s fair enough, they guessed, but the story also dredged up a tragic
incident from Simpson’s high school years, one that had haunted him
for years. After a night of drinking at Simpson’s house in the spring of
1982, a friend stumbled into the road and was killed by a car. Simpson’s
mother was arrested and charged with allowing her son to throw a party
with alcohol. (The charges were later dismissed.) The anecdote felt like a
cheap shot, and it landed. Simpson and his mother had to relive the hor
rible episode all over again.
“Well, that was gratuitous:’ Simpson told Fritsch. “Yeah,” he replied.
“Really uncool:’
The wind then shifted again, this time for the better. A day after the
Times story ran, Dianne Feinstein, the normally reserved Democratic
senator from California, abruptly released the confidential transcript of
Simpson’s testimony before the Judiciary Committee—just as Fritsch
and Simpson had called for in their op-ed a week earlier. She had had
enough of Republican spin. “The innuendo and misinformation circu
lating about the transcript are part of a deeply troubling effort to under
mine the investigation into potential collusion and obstruction of
justice:’ she said.
For the first time, the press and the public now had a firsthand ac
count of the long history of Orbis’s and Fusion’s investigations into
EXHIBIT B

DISTRICT OF COLUMBIA
–––––––––––––––––––––––––––––––––––––––––––X
:
MIKHAIL FRIDMAN, PETR AVEN, AND : Case 1:17-CV-02041 (RJL)
GERMAN KHAN, :
:
Plaintiffs, :
:
-v- :
:
BEAN LLC (A/K/A FUSION GPS) AND GLENN :
SIMPSON, :
:
Defendants. :
:
–––––––––––––––––––––––––––––––––––––––––––X
PLAINTIFFS’ SUPPLEMENTAL RESPONSES AND OBJECTIONS TO

DEFENDANTS’ FIRST SET OF INTERROGATORIES
Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure (the “Federal
Rules”) and the Local Rules of the District Court for the District of Columbia (the “Local
Rules”), Plaintiffs Mikhail Fridman, Petr Aven, and German Khan hereby supplement their
November 11, 2019 initial responses and objections (“Initial Responses”) to Defendants’ First
Set of Interrogatories, dated October 11, 2019 (each an “Interrogatory,” and together, the
“Interrogatories”), as follows:
GENERAL STATEMENTS AND OBJECTIONS
A. These supplemental responses and objections (each a “Response” and together the
“Responses”) are being provided based upon documents and information presently available and
known to Plaintiffs.
B. All objections, responses, reservations of rights, and definitions from Plaintiffs’
Initial Responses are applicable to these Responses and incorporated by reference as though fully
set forth.
9565311.3
C. In supplementing their Responses, Plaintiffs are responding only based upon
information within Plaintiffs’ possession, custody, or control. As indicated in Plaintiffs’ Initial
Responses, Plaintiffs object to Interrogatories that seek or are intended to seek information
within the possession, custody, or control of non-parties.
D. Plaintiffs continue to reserve all rights to further supplement, amend, modify, or
clarify these Responses. If there is no supplemental response to specific Interrogatories being
provided at this time, such specific Requests are not reflected below.
E. The foregoing General Statements and Objections are incorporated by reference
in each of the specific Responses appearing below.
SUPPLEMENTAL RESPONSES AND OBJECTIONS
INTERROGATORY NO. 2
Identify all of the specific statements of and concerning you that you allege in this action
amount to defamation by the Defendants and for each of those statements, explain the alleged
defamatory meaning of the statement as it applies to you.
RESPONSE TO INTERROGATORY NO. 2
The heading of CIR 112, “RUSSIA/US PRESIDENTIAL ELECTION: KREMLIN-
ALPHA GROUP COOPERATION,” coupled with Plaintiffs and Alfa being the subject of CIR
112, falsely suggests that Plaintiffs and Alfa cooperated with a Kremlin-orchestrated illegal
campaign to interfere with the 2016 U.S. presidential election.
A second defamatory statement in CIR 112 reads as follows: “Significant favours
continued to be done in both directions, primarily political ones for PUTIN and business/legal
ones for Alpha.” That sentence is defamatory by accusing Plaintiffs of corruption and bribery in
their relationship with Putin. It has that meaning because the alleged provision of business and
economic “favors” by a government official (in this case Putin) to private business people (in
this case Plaintiffs) in exchange for the provision of services beneficial to the individual
2
9565311.3
government official (political favors to Putin) who is causing the government to provide business
and economic favors describes bribery. CIR 112 is not explicit about when the corrupt, alleged
exchange of favors began. However, by using the word “continued,” it does clearly allege that a
corrupt relationship and bribery were continuing in 2016, when CIR 112 was written. Therefore,
for the purposes of this lawsuit, Plaintiffs’ claim treats the allegation of corruption and bribery—
exchanging political favors for economic/business favors—as an allegation of conduct during
2016.
The following content of CIR 112 is also defamatory:
during the 1990s GOVORUN had been Head of Government Relations at Alpha Group and in
reality, the “driver” and “bag carrier” used by FRIDMAN and AVEN to deliver large amounts of
illicit cash to the Russian president, at that time deputy Mayor of St Petersburg. Given that and
the continuing sensitivity of the PUTIN-Alpha relationship, and need for plausible deniability,
much of the contact between them was now indirect and entrusted to the relatively low profile
GOVORUN.
The defamatory meaning of the first sentence of this passage is an accusation of
bribery—illicit cash paid by Plaintiffs Fridman and Aven to a government official, Vladimir
Putin—through an intermediary, Govorun. The defamatory meaning of the second sentence of
this passage is that it accuses the Plaintiffs of constructing their present-day form of “contact”
with Putin as indirect because of the alleged past cash bribes delivered through Govorun. This
sentence ties the Plaintiffs current actions to the Govorun bribery allegation with the words
“given that”—which clearly refer back to the Govorun bribery allegation. The statement that
Plaintiffs “entrust” “much of” of their contact with Putin in 2016 to Govorun is also defamatory
in the context of the allegation that Govorun previously acted for the Plaintiffs as the “bag
carrier” of their “illicit cash.”
9565311.3
Dated: New York, New York

May 18, 2020
By: ___________________________________
Alan S. Lewis
John J. Walsh
2 Wall Street
New York, NY 10005
Tel: (212) 732-3200
Kim H. Sperduto
SPERDUTO THOMPSON & GASSLER PLC
Washington, DC 20006
Tel: (202) 408-8900
9565311.3
VERIFICATION
I, MIKHAIL FRIDMAN, am a plaintiff in the above-captioned action. I have read the

Supplemental Responses and Objections to Defendants’ First Set of Interrogatories dated May 18,
2020, and know the contents thereof and, as the responses pertain to me individually, I declare
under penalty of perjury under the laws of the United States of America that they are true and
correct to my knowledge, except as to matters therein stated to be alleged upon information and
belief, and as to those matters, I declare under penalty of perjury under the laws of the United
States of America that I believe them to be true as they pertain to me individually.
Executed on 18 May 2020.
____________________________
Mikhail Fridman
VERIFICATION
I, GERMAN KHAN, am a plaintiff in the above-captioned action. I have read the

Supplemental Responses and Objections to Defendants' First Set of Interrogatories dated May 18,
2020, and know the contents thereof and, as the responses pertain to me individually, I declare
under penalty of perjury under the laws of the United States of America that they are true and
correct to my knowledge, except as to matters therein stated to be alleged upon information and
belief, and as to those matters, I declare under penalty of perjury under the laws of the United
States of America that I believe them to be true as they pertain to me individually.
Executed on ff; k, Pap; 20W
Ge
EXHIBIT C

MIKHAIL FRIDMAN, PETR AVEN, and

GERMAN KHAN,
Plaintiffs,
Civil Case No. 1:17-cv-2041-RJL
v.
BEAN LLC a/k/a FUSION GPS, and GLENN

SIMPSON,
Defendants.
DEFENDANTS’ FIRST AMENDED RULE 26(a)(1) INITIAL DISCLOSURES
Pursuant to Federal Rules of Civil Procedure 26(a)(1) and 26(e), Defendants Bean LLC
(a/k/a Fusion GPS) and Glenn Simpson, through undersigned counsel, make the following
amended initial disclosures. These disclosures are based on information known and reasonably
available to Defendants which Defendants believe they may use to support their claims and
defenses. As discovery progresses, Defendants may learn of additional potential witnesses and
documents. Therefore, Defendants reserve the right to supplement these initial disclosures.
By providing these initial disclosures, Defendants do not represent that they are identifying
every document, tangible thing, or witness possibly relevant to this action. In addition, Defendants
make these disclosures without in any way waiving their right to object to any discovery request
or proceeding involving or relating to the subject matter of these disclosures, including privilege,
relevance, undue burden, or any other grounds. These disclosures are not an admission by
Defendants regarding any matter.
1
1. Individuals Likely to Have Discoverable Information That Defendants May Use

to Support Their Claims or Defenses
Individuals likely to have discoverable information that Defendants may use to support
their claims or defenses are set forth below.
Name Subject Matter Address, if known

Glenn Simpson Full knowledge of dispute c/o Joshua A. Levy
Cunningham Levy Muse
LLP
1401 K St. NW, Suite 600
Peter Fritsch Full knowledge of dispute c/o Joshua A. Levy

LLP
Jake Berkowitz Full knowledge of dispute c/o Joshua A. Levy

LLP
Jason Felch Full knowledge of dispute c/o Joshua A. Levy

LLP
Petr Aven Full knowledge of dispute
Mikhail Fridman Full knowledge of dispute
German Khan Full knowledge of dispute
Corporate All entities affiliated with Alfa; Alfa’s

representative of ties to the Kremlin and Vladimir Putin;
Alfa Group Alfa’s investments in U.S. companies;
Plaintiffs’ access to Alfa public relations
staff; events related to topics in CIR 112;
2
any connections or communications

between a server linked to the Trump
Organization and Alfa server(s)
Alfa Fellowship Relevant conduct of Plaintiffs; Plaintiffs’ c/o Cultural Vistas
Program corporate communications, positions, and 233 Broadway
representative statements concerning U.S. politics, U.S. Suite 2120
non-profits and foundations, the New York, New York 10279
presidential election, the Trump
Organization; Plaintiffs’ wealth and
notoriety; Plaintiffs’ interactions with the
media; Plaintiffs’ roles in the business
world; Plaintiffs’ donations to charitable
organizations and foundations; Plaintiffs’
public relations activities in the United
States
Representative of Plaintiffs’ roles in the business world;
Amsterdam Trade Plaintiffs’ access to public relations staff;
Bank Plaintiffs’ communications and
statements regarding relationships with
the Kremlin/Putin; Plaintiffs’ wealth and
notoriety
Corporate Relevant conduct of Plaintiffs; Plaintiffs’ APCO Worldwide
representative of roles in the business world; Plaintiffs’ 90 Long Acre
APCO control of Alfa; Plaintiffs’ access to London WC2E 9RA UK
public relations staff; Plaintiffs’
relationships with the Kremlin/Putin
Howard Ash Plaintiffs’ investments in the U.S.; 3363 NE 163rd Street, Suite
Plaintiffs’ roles in the business world; 705, North Miami
Plaintiffs’ control of Alfa Beach, Florida 33160
Anders Aslund Relevant conduct of Plaintiffs, including Atlantic Council, 1030 15th
Plaintiffs’ investments in the United St NW, Washington, DC
States; Plaintiffs’ communications, 20005
positions, and statements concerning U.S.
politics, U.S. non-profits and
foundations, the presidential election, the
Trump Organization; Plaintiffs’ wealth
and notoriety; Plaintiffs’ interactions with
the media; Plaintiffs’ roles in the business
States
3
Representative of Relevant conduct of Plaintiffs; speeches 1030 15th Street NW, 12th
Atlantic Council by Plaintiffs at Atlantic Council events; floor, Washington, D.C.
Plaintiffs’ meetings with US officials; 20005
contributions by Plaintiffs to Atlantic
Council; Plaintiffs as public figures;
Plaintiffs’ public relations activities in
the United States; Plaintiffs’ lobbying
efforts in the United States and abroad;
relationship between Plaintiffs and
Kremlin/Putin
James A. Baker III Plaintiffs’ notoriety; Plaintiffs’

communications, positions, and
statements concerning U.S. politics, U.S.
non-profits and foundations; Plaintiffs’
roles in the business world; Plaintiffs’
States
James Baker Relevant conduct of David Corn and
Chris Steele; Recipients of CIR 112;
research related to matters in CIR 112;
events related to topics in CIR 112;
delivery of CIR 112; Russian interference
in and/or influence on U.S. policy and/or
U.S. politics; Russian interference in
and/or influence on U.S. elections; FBI’s
knowledge of CIR 112; Government
investigations into Russian interference
in U.S. politics, elections, and policy
Mike Baker Plaintiffs’ investments in the United Diligence USA LLC, New
States; Plaintiffs’ roles in the business York
world; Plaintiffs’ interactions with the 33 Irving Place
media; Plaintiffs’ involvement in Alfa 3rd Floor
dispute with IPOC; Plaintiffs’ public New York, NY 10003
relations activities in the United States
Gov. Haley Plaintiffs’ lobbying efforts in the U.S. BGR Group, 601 13th St
Barbour and abroad; Plaintiffs’ interactions with NW, Washington, DC 20005
the media; Plaintiffs’ public relations
activities in the United States; Plaintiffs’
and Alfa’s roles in the business world
Edward Relevant conduct of Plaintiffs; Plaintiffs’
Baumgartner roles in the business world; Plaintiffs’
ties, communications, meetings, and
relations with the Kremlin, Vladimir
Putin, and those representing them or
acting on their behalf; Alfa, including
4
entities affiliated with Alfa; Alfa’s ties to

the Kremlin and Vladimir Putin; Alfa’s
investments in U.S. companies; research
related to matters in CIR 112
Ken Bensinger Relevant conduct of Buzzfeed; recipients
of CIR 112; delivery of CIR 112
Corporate Plaintiffs’ lobbying efforts in the U.S.
representative of and abroad; Plaintiffs’ interactions with
BGR the media; Plaintiffs’ public relations
activities in the United States
Jeffrey Birnbaum Plaintiffs’ lobbying efforts in the U.S. BGR Group, 601 13th St
and abroad; Plaintiffs’ interactions with NW, Washington, DC 20005
Sir Leonard Plaintiffs’ roles in the business world; Access Industries
Blavatnik Plaintiffs’ access to public relations staff; 40 West 57th Street
Plaintiffs’ communications and 28th Floor
statements regarding relationships with New York, New York 10019
the Kremlin/Putin; Plaintiffs’ wealth and
notoriety; Plaintiffs’ investments in the
United States; Plaintiffs’ ties,
communications, meetings, and relations
with the Kremlin, Vladimir Putin, and
those representing them or acting on their
behalf; Plaintiffs’ accumulation of wealth
Corporate Relevant conduct of Plaintiffs, Alfa;
representative for Plaintiffs’ roles in the business world;
BP events related to topics in CIR 112;
Plaintiffs’ notoriety; Plaintiffs’
relationships with the Kremlin/Putin
Christopher Brose recipients of CIR 112, delivery of CIR
112
Nicholas Burgess Plaintiffs’ roles in the business world; 21 Tudor St, Temple,
Plaintiffs’ control of Alfa London EC4Y 0DJ, UK
William J. Burns Plaintiffs’ interactions with the Carnegie President, Carnegie

Endowment for International Peace; Endowment for International
Plaintiffs’ relationship with the Peace,
Kremlin/Putin 1779 Massachusetts Ave
NW, Washington, DC 20036
Chris Burrows Relevant conduct of Orbis and

Christopher Steele; Christopher Steele,
including his experience, work, process,
and engagement by Defendants;
5
Richard Burt Public relations and lobbying efforts of McLarty Associates

Plaintiffs in the US and abroad; 900 17th Street NW, Suite
Plaintiffs’ visits to the White House and 800
contacts with White House officials; Washington, DC 20006
relevant conduct of Plaintiffs; Plaintiffs’
investments in the US; Plaintiffs’
interactions with the media; Plaintiffs’
relations with the Kremlin,
Vladimir Putin, and those representing
them or acting on their behalf; Plaintiffs’
wealth and notoriety; Plaintiffs’
non-profits and foundations, the
Organization; Plaintiffs’ contacts with the
Trump Organization, the Trump
Campaign, and the Trump
Administration; Russian interference in
and/or influence on U.S policy and/or in
U.S. elections; Alfa’s relevant conduct,
including all entities affiliated with Alfa,
Alfa’s ties to the Kremlin and Vladimir
Putin, and Alfa’s investments in U.S.
companies
Fred Burton Relevant conduct of Plaintiffs and Alfa; Stratfor Enterprises LLC
Plaintiffs’ ties, communications, 221 W. 6th Street
meetings, and relations with the Kremlin, Suite 400
Vladimir Putin, and those representing Austin, Texas 78701
them or acting on their behalf
Groslyn Burton Plaintiffs’ visits to the White House and The Asia Group
contacts with White House officials 2101 L Street NW
Suite 310
Jean Camp Relevant conduct of Alfa and the

Plaintiffs concerning Alfa servers
Corporate Plaintiffs’ and Alfa’s interactions with 1779 Massachusetts Ave
representative of Carnegie Endowment for International NW, Washington, DC 20036
Carnegie Peace; Plaintiffs’ donations to charitable
Endowment for organizations and foundations
International Peace
6
Charlie Carr Relevant conduct of Plaintiffs and Alfa; C and F Partners Limited
Plaintiffs’ and Alfa’s relationship with 64 Baker Street, 1St Floor
the Kremlin/Putin; Plaintiffs as public London W1U 7GB UK
figures
Representative of Plaintiffs’ ties, communications, 1025 Connecticut Avenue
Center for the meetings, and relations with the Kremlin, NW, Suite 1200,
National Interest Vladimir Putin, and those representing Washington, D.C. 20036
statements concerning U.S. politics; U.S.
non-profits and foundations; the
presidential election; the Trump
Organization; Government investigations
into Russian interference in U.S. politics,
elections, and policy
Representative of Plaintiffs contacts with Chabad House; Chabad House at Harvard

Chabad House at Plaintiffs’ donations to charitable 38 Banks Street
Harvard organizations and foundations Cambridge, MA 02138
Jim Cobery Plaintiffs’ donations to charitable VP & General Counsel, The

organizations and foundations; Plaintiffs’ Kraft Group, The Kraft
involvement with the Genesis Prize Group, One Patriot Place,
Foundation Foxborough, MA 02035
James Comey Relevant conduct of Plaintiffs, Alfa;

FBI’s knowledge of CIR 112;
Government investigations into Russian
interference in U.S. politics, elections,
and policy; Russian interference in U.S.
elections; Russian interference in and/or
influence on U.S policy; Russian
interference in and/or influence on U.S.
politics
Council on Foreign Plaintiffs’ donations to charitable
Relations organizations and foundations; Plaintiffs’
notoriety; Plaintiffs’ communications, 58 East 68th Street, New
positions, and statements concerning U.S. York, NY 10065
politics, US-Russian policy, U.S. non-
profits and foundations; Plaintiffs’
foreign policy experience
Jonathan Davis Relevant conduct of Plaintiffs, including Kirkland & Ellis LLP, 601
business roles, transactions, notoriety; Lexington Avenue
New York, NY 10022
7
relevant conduct and transactions of Alfa;

events related to topics in CIR 112
Representative of Relevant conduct of Plaintiffs, Alfa;
the U.S. FBI’s knowledge of CIR 112;
Department of Government investigations into Russian
Justice interference in U.S. politics, elections,
politics
Dimitry Dikman Relevant conduct of Plaintiffs; Plaintiffs’ Genesis Philanthropy Group,
creation and involvement in Genesis 499 Seventh Avenue, 15th
Philanthropy Group; Plaintiffs’ donations Floor North, New York, NY
to charitable organizations and 10018
foundations; Plaintiffs’ involvement with
the Genesis Prize Foundation
Jill Dougherty Relations between Plaintiffs and the 1621 N 40th Street
media Seattle, WA 98103
Robert Dudley Relevant conduct of Plaintiffs, including BP, 50I Westlake Park
business roles, transactions, notoriety; Boulevard Houston, TX
relevant conduct and transactions of Alfa; 77079
David Edwards Relevant conduct of Plaintiffs, including Skadden Arps
business roles, transactions, notoriety; 40 Bank St, Canary Wharf,
relevant conduct and transactions of Alfa; London E14 5DS, UK
Maria Faasen (née Relevant conduct of Plaintiffs and Alfa;
Putin) Plaintiffs’ relations with Vladimir Putin
and family
Representative of Relevant conduct of Plaintiffs, Alfa;
the U.S. Federal FBI’s knowledge of CIR 112;
Bureau of Government investigations into Russian
Investigation interference in U.S. politics, elections,
politics
Jeffrey W. Plaintiffs’ investment in the United Carlyle Group, 1001
Ferguson States; publication of such investment Pennsylvania Avenue NW
Oleg Firer Plaintiffs’ investments in the U.S.; Net Element, 3363 NE
Plaintiffs as public figures; Plaintiffs’ 163RD Street, Suite 705,
control of Alfa
8
North Miami
Beach, FL 33160
Michael Froman Plaintiffs’ relationships with the

Kremlin/Putin; Plaintiffs’
statements regarding foreign policy;
Plaintiffs’ public relations and lobbying
efforts in the U.S. and abroad; Plaintiffs’
acting on their behalf
Mark Galeotti Plaintiffs’ relationship with the
Kremlin/Putin; relationships between
Russian oligarchs and the Kremlin/Putin;
influence of Russian oligarchs on the
Kremlin/Putin; corruption in Russia; the
privatisation of Russia
Toby Gati Relevant conduct of Plaintiffs, including 1177 22nd Street NW, Unit
Plaintiffs’ investments in the United 7C
States; Plaintiffs’ communications, Washington, DC 20037
politics, U.S. non-profits and
foundations; Plaintiffs’ wealth and
media; Plaintiffs as public figures;
the United States; relationships between
Russian oligarchs and the Kremlin/Putin
Gennady Gazin Relevant conduct of Plaintiffs; Plaintiffs’ Genesis Philanthropy Group,
the Genesis Prize Foundation;
Genesis Relevant conduct of Plaintiffs; Plaintiffs’ 499 Seventh Avenue,
Philanthropy Group creation and involvement in Genesis 15th Floor North,
corporate Philanthropy Group; Plaintiffs’ donations New York, NY 10018
representative to charitable organizations and
foundations Plaintiffs’ involvement with
the Genesis Prize Foundation;
Thomas W. Relevant conduct of Plaintiffs and Alfa; Director, Hoover Institution
Gilligan Plaintiffs’ donations to charitable 434 Galvez Mall
organizations and foundations Stanford University
Stanford, CA 94305-6003
9
Jose Grinda Investigations into alleged illegal Fiscalia Especial Contra La

Gonzalez transactions by Mikhail Fridman Corrupcion y La
Criminalidad Organizada
Manuel Silvela, 4
Madrid, 28010 Spain
Oleg Govorun Relevant conduct of Plaintiffs, Alfa,

Putin, Kremlin; events related to topics in
CIR 112
David Grenker Relevant conduct of Plaintiffs, including Kirkland & Ellis LLP, 601
relevant conduct and transactions of Alfa; New York, NY 10022
Steven Hall Relationship between Plaintiffs and
Kremlin/Putin
John Halsted Relevant conduct of Mikhail Fridman; Pamplona Capital
national security concerns regarding Management, 375 Park
investment by Mikhail Fridman Avenue, 17th Floor, New
York, NY 10152
Andrew Hayes Public relations activities of Plaintiffs; Hudson Sandler, 25

Plaintiffs as public figures; Plaintiffs’ Charterhouse Square
interactions with the media; London
EC1M 6AE
Fred Hiatt Plaintiffs’ relations with the media; Washington Post editorial
communications with Plaintiffs and their board
media representatives; knowledge of 1301 K Street NW
Plaintiffs’ media representatives Washington, DC 20071
David Higgins Relevant conduct of Plaintiffs, including Kirkland & Ellis LLP, 30 St
business roles, transactions, notoriety; Mary Axe, London, EC3A
relevant conduct and transactions of Alfa; 8AF, United Kingdom
Representative of Public relations activities of Plaintiffs;
Hill+Knowlton Plaintiffs as public figures; Plaintiffs’
Strategies interactions with the media;
Daniel Hoffman Oligarchs and their ties to the Kremlin;
relevant conduct of Alfa and Plaintiffs;
Plaintiffs’ ties, communications,
meetings, and relations with the Kremlin,
10
Karl V. Hopkins Relevant conduct of Plaintiffs; speeches SNR Denton LLP, 1900 K
by Plaintiffs at Atlantic Council events; Street NW, Washington, DC
Kremlin/Putin
Matthias Horbach Relevant conduct of Plaintiffs, including
business roles, transactions, notoriety;
Plaintiffs as public figures
Robert Hormats Meetings with Plaintiffs; Kissinger Associates
communications and their 350 Park Ave #26, New
representatives; relationship between York, NY 10022
Plaintiffs and US government officials
Corporate Public relations activities of Plaintiffs; 25 Charterhouse Square
representative of Plaintiffs as public figures; Plaintiffs’ London
Hudson Sandler interactions with the media; EC1M 6AE
David Ignatius Plaintiffs’ relations with the media;

communications with Plaintiffs and their
media representatives; knowledge of
Plaintiffs’ media representatives;
Kremlin/Putin
Andrey Illiaronov Relationship between Plaintiffs and CATO Institute
Kremlin/Putin; Plaintiffs’ public 1000 Massachusetts Avenue
appearances; Plaintiffs’ and Alfa’s NW
business tactics; Plaintiffs as public Washington, DC 20001
figures
Carl Jenkins Plaintiffs’ roles in the business world; Global Head of Governance,
Plaintiffs’ notoriety; Plaintiffs’ business Risk, Investigations and
tactics; Plaintiffs’ dispute with IPOC Disputes for Kroll
55 East 52nd Street New
York New York 10055
Ryan Junck Plaintiffs’ relationships with the

11

Adrian Karatnycky Lobbying on behalf of Plaintiffs and Myrmidon Group LLC
Alfa; Plaintiffs’ relations with the media 53 Saint Mark’s Place
and US government officials; access to New York, New York 10003
public relations
Keenan Center Plaintiffs’ interactions with the media;
corporate Plaintiffs’ wealth and notoriety;
representative Plaintiffs’ donations to charitable
investments in the United States;
Plaintiffs as public figures; Plaintiffs’
States; Plaintiffs’ lobbying efforts in the
United States and abroad
Fred Kempe Relevant conduct of Plaintiffs; speeches Atlantic Council, 1030 15th
by Plaintiffs at Atlantic Council events; St NW, Washington, DC
Kremlin/Putin
Alexa King Communications between Plaintiffs/Alfa 601 McCarthy Blvd.

and the Trump Campaign/Trump Milpitas, CA 95035
Organization
Corporate Relevant conduct of Plaintiffs, including
representative of business roles, transactions, notoriety;
Kirkland & Ellis relevant conduct and transactions of Alfa;
LLP events related to topics in CIR 112;
Denis Plaintiffs’ control of Alfa; TNK-BP Skadden Arps
Klimentchenko transaction; Plaintiffs’ transactions and 40 Bank St, Canary Wharf,
their relationship with the Kremlin/Putin; London E14 5DS, UK
favors exchanged between Putin and
Plaintiffs
Alex Knaster Relevant conduct of Mikhail Fridman; Pamplona Capital
national security concerns regarding Management, 25 Park Lane,
investment by Mikhail Fridman London W1K 1RA, England,
United Kingdom
12
Yuri Koshkin Relevant conduct of Plaintiffs and Alfa; Trident Group L.L.C., 1901
Plaintiffs’ ties, communications, N. Fort Myer Driver,
meetings, and relations with the Kremlin, Arlington VA 22209
Robert Kraft Plaintiffs’ donations to charitable The Kraft Group,
organizations and foundations; Plaintiffs’ One Patriot Place,
involvement with the Genesis Prize Foxborough, MA 02035
Foundation;
David Kramer Delivery and receipt of CIR 112;
privileged publication
Corporate Plaintiffs’ roles in the business world;
representative of Plaintiffs’ notoriety; Plaintiffs’ business
Kroll tactics; Plaintiffs’ dispute with IPOC;
Defendants’ background knowledge of
Alfa and the Plaintiffs; Plaintiffs’ and
Alfa’s relationship with the
Kremlin/Putin
Jeremy M. Kroll Plaintiffs’ roles in the business world; K2 Intelligence, 845 Third
Plaintiffs’ notoriety; Plaintiffs’ business Avenue, New York, NY
tactics; Plaintiffs’ dispute with IPOC; 10022
Kremlin/Putin
Jules B. Kroll Plaintiffs’ roles in the business world; K2 Intelligence, 845 Third
Plaintiffs’ notoriety; Plaintiffs’ business Avenue, New York, NY
tactics; Plaintiffs’ dispute with IPOC; 10022
Kremlin/Putin
Simon Kukes Plaintiffs’ roles in the business world;
Plaintiffs’ notoriety; Plaintiffs’ business Pacific Energy Development
tactics; Plaintiffs’ ties, communications, 4125 Blackhawk Plaza Cir #
meetings, and relations with the Kremlin, 201, Danville, CA 94506
Josh Kushner Plaintiffs’ investments in the U.S.; Thrive Capital
Plaintiffs’ wealth and notoriety; 295 Lafayette Street Suite
Plaintiffs’ roles in the business world 701 New York, NY 10012
James C. Langdon Plaintiffs’ roles in the business world; Senior Counsel, Akin Gump
Jr. Plaintiffs’ control of Alfa; Plaintiffs’ Strauss Hauer & Feld LLP
business tactics 2001 K Street NW
13
Amb. Ronald Plaintiffs’ donations to charitable Ronald S. Lauder

Lauder organizations and foundations; Plaintiffs’ Foundation, 767 5th Ave.,
public relations activities in the United Ste. 4200, New York City,
States; Plaintiffs’ lobbying efforts in the NY 10153-0185
United States and abroad; Plaintiffs’
interactions with the media
Vladimir Lechtman Relevant conduct of Plaintiffs regarding Jones Day, Ducat III, 12th
creation of LetterOne; Plaintiffs’ control Floor 6 Gasheka Street
of Alfa 125047 Moscow, Russia
Eric Lichtblau Receipt and delivery of CIR 112
David Lipton Relevant conduct of Plaintiffs; Plaintiffs’ International Monetary Fund

public relations activities in the United 700 19th Street NW
States; Plaintiffs’ lobbying efforts in the Washington, DC 20431
United States and abroad; Plaintiffs’
roles in the business world
Mark MacDougall Plaintiffs’ relationship with the Kremlin; Akin Gump Strauss Hauer &
Plaintiffs’ notoriety; Plaintiffs’ conduct Feld LLP
regarding the IPOC dispute; Defendants’ 2001 K Street NW
knowledge of Plaintiffs; Plaintiffs’ use of Washington, DC 20006
Kroll
Maria Mammina Relevant conduct of Plaintiffs; Plaintiffs’ 628 Willoughby Avenue
communications, positions, and Apartment 3
statements concerning U.S. politics, U.S. Brooklyn, New York 11206
Organization; Plaintiffs’ wealth and
media; Plaintiffs’ roles in the business
States
Kevin Mandia Any connections or communications 601 McCarthy Blvd.
between a server linked to the Trump Milpitas, CA 95035
Organization and Alfa server(s)
Corporate Any connections or communications
representative of between a server linked to the Trump
Mandiant Organization and Alfa server(s)
Peter Martelli Relevant conduct of Plaintiffs, including Kirkland & Ellis LLP, 601
14
relevant conduct and transactions of Alfa; New York, NY 10022,

events related to topics in CIR 112 United States
Andrew McCabe Relevant conduct of Plaintiffs, Alfa;

politics
Michael McFaul Plaintiffs’ relationships with the
Joy McGrath Relevant conduct of Petr Aven; Aven’s Chief of Staff, Office of
communications, positions, and President, Yale University, 3
statements concerning U.S. politics, U.S. Prospect Street, New Haven,
non-profits and foundations, the CT 06511
Organization; Aven’s wealth and
notoriety; Aven’s donations to charitable
States
Corporate Public relations and lobbying efforts of 900 17th Street NW, Suite
representative of Plaintiffs in the US and abroad; 800
McLarty Associates Plaintiffs’ visits to the White House and Washington, DC 20006
contacts with White House officials;
15

companies
Ed Mermelstein Public relations and lobbying efforts of 20 W. 36th Street, 12th Floor
Plaintiffs in the US and abroad; New York, NY 10018
Plaintiffs’ investments in the US;
Plaintiffs’ interactions with the media;
Plaintiffs’ roles in the business world;
Plaintiffs’ communications, positions,
and statements concerning U.S. politics,
U.S. non-profits and foundations, the
Organization; Alfa’s relevant conduct,
companies
Clark R. Moore Plaintiffs as public figures; Plaintiffs’ Pacific Energy Development
notoriety; Plaintiffs’ business tactics; 4125 Blackhawk Plaza Cir #
Plaintiffs’ ties, communications, 201, Danville, CA 94506
Alejandro Moreno Relationship between Plaintiffs and Access Industries
Kremlin/Putin 40 West 57th Street
28th Floor
New York, New York 10019
Michael Movsovich Relevant conduct of Plaintiffs, including Kirkland & Ellis LLP, 601
16
Myrmidon Group Lobbying on behalf of Plaintiffs and

LLC corporate Alfa; Plaintiffs’ relations with the media
representative and US government officials; access to
public relations
Corporate Public relations and lobbying efforts of 1048 Fifth Avenue
representative of Plaintiffs in the US and abroad; New York, New York 10028
Neue Galerie Plaintiffs’ investments in the US;
Plaintiffs’ donations to the Neue Galerie
Corporate Receipt and delivery of CIR 112

representative of
the New York
Times
Eric Nitcher Relevant conduct of Plaintiffs, including General Counsel for BP

business roles, transactions, notoriety; 50I Westlake Park Boulevard
relevant conduct and transactions of Alfa; Houston, TX 77079
Victoria Nuland Relevant conduct of Plaintiffs, Alfa;
Government’s receipt, delivery, and
in US politics, elections, and policy;
Russian interference in US elections;
Russian interference in and/or influence
on US policy; Russian interference in
and/or influence on US politics;
communications with Plaintiffs;
Plaintiffs’ communications and
relationships with US government
officials
Representative of Relationships, ties, or communications
the U.S. Office of between Plaintiffs and Vladimir Putin
Foreign Assets and/or the Kremlin; relevant conduct of
Control (OFAC) oligarchs and Putin; sanctions on Russian
oligarchs and businesses
Richard Palmer Plaintiffs as public figures; Plaintiffs’ Cachet International Inc.
notoriety; Plaintiffs’ business tactics; 8905 Potomac Station Lane
Plaintiffs’ ties, communications, Potomac, Maryland 20854
them or acting on their behalf; Alfa’s
business tactics; Alfa’s ties,
communications, and relations with the
17
Kremlin, Vladimir Putin, and those

representing them or acting on their
behalf; events related to topics in CIR
112
Javier Perez Dolset Relevant conduct of Plaintiff Mikhail
Fridman and Alfa entities;
The Peter G. Plaintiffs’ donations to charitable 1750 Massachusetts Ave.,
Peterson Institute organizations and foundations; Plaintiffs’ NW, Washington DC 20009
for International roles in the business world; Plaintiffs’
Economics notoriety; Plaintiffs’ communications,
corporate positions, and statements concerning U.S.
representative politics; U.S. non-profits and foundations
Stan Polovets Public relations and lobbying efforts of 9 W 84th St., Apt. 1, New
Plaintiffs in the US and abroad; York, NY 10024
Plaintiffs’ visits to the White House and
contacts with White House officials;
companies
Adam Posen Plaintiffs’ donations to charitable The Peter G. Peterson

organizations and foundations; Plaintiffs’ Institute for International
roles in the business world; Plaintiffs’ Economics, 1750
notoriety; Plaintiffs’ communications, Massachusetts Ave., NW,
Washington DC 20009
18

politics, U.S. non-profits and foundations
Bill Priestap Relevant conduct of Plaintiffs, Alfa;
politics
Vladimir Putin Full knowledge of dispute; events
described in CIR 112;
Stephen Rademaker Plaintiffs’ lobbying efforts in the U.S. Covington & Burling
and abroad; Plaintiffs’ interactions with 850 10th St NW,
the media; Plaintiffs’ public relations Washington, DC 20001
Rand Corporation Plaintiffs’ donations to charitable 1776 Main Street PO Box
organizations and foundations; Plaintiffs’ 2138, Santa Monica, CA
roles in the business world; Plaintiffs’ 90407-2138
notoriety; Plaintiffs’ communications,
politics, US-Russian policy, U.S. non-
profits and foundations; Plaintiffs’
foreign policy experience
Tom Reed Plaintiffs’ roles in the business world;
Plaintiffs as public figures; Plaintiffs’
control of Alfa; Plaintiffs’ business
tactics
Alexey Relationship between Plaintiffs and 43 Berkeley Square London,
Reznikovich Kremlin/Putin; Plaintiffs’ control of Alfa; W1J 5AP United Kingdom
Plaintiffs’ corrupt and criminal activity
Ed Rogers Plaintiffs’ lobbying efforts in the U.S. BGR Group, 601 13th St
Mathew Rojansky Plaintiffs’ interactions with the media; Director, Wilson Center,
Plaintiffs’ wealth and notoriety; Kennan Institute, Ronald
Plaintiffs’ donations to charitable Reagan Building and
organizations and foundations; Plaintiffs’ International Trade Center
investments in the United States; One Woodrow Wilson Plaza,
Plaintiffs’ roles in the business world; 1300 Pennsylvania Ave. NW
Plaintiffs’ public relations activities in Washington, DC 20004-3027
19

efforts in the United States and abroad
Jack Rosen Relevant conduct of Fridman; Fridman’s Rosen Partners LLC, 745
efforts to invest in US real estate Fifth Avenue, 30th floor,
New York, NY 10151
Laura Rosenberger Plaintiffs’ relationships with the

David M. Plaintiffs’ investments in the United Carlyle Group
Rubenstein States; Plaintiffs’ wealth and notoriety 1001 Pennsylvania Avenue
NW
Ilia Salita Relevant conduct of Plaintiffs; Plaintiffs’ Genesis Philanthropy Group,

the Genesis Prize Foundation; Plaintiffs’
public appearances
Peter Salovey Relevant conduct of Petr Aven; Aven’s Office of President, Yale
communications, positions, and University, 3 Prospect Street,
statements concerning U.S. politics, U.S. New Haven, CT 06511
States
Natan Sharansky Relevant conduct of Plaintiffs; Plaintiffs’ Genesis Philanthropy Group,
20

public appearances
Plaintiffs’ ties, communications, 8905 Potomac Station Lane

Dimitri Simes meetings, and relations with the Kremlin, Potomac, Maryland 20854
non-profits and foundations; the
Organization; Government investigations
into Russian interference in U.S. politics,
elections, and policy
Scott V. Simpson Plaintiffs’ corrupt and criminal activity; Skadden Arps
Plaintiff’s control of Alfa 40 Bank St, Canary Wharf,
London E14 5DS, UK
Ben Smith Relevant conduct of Buzzfeed, recipients

of CIR 112; delivery of CIR 112
Jill W. Smith Relevant conduct of Plaintiffs; Plaintiffs’ Genesis Philanthropy Group,
public appearances
Christopher Steele Experience, work, process, and

engagement by Defendants; his
communications with the FBI, Senator
John McCain, the U.S. Department of
Justice, and other governmental agencies
and officials; CIR 112, including
recipients of CIR 112, research related to
matters in CIR 112, events related to
topics in CIR 112, and delivery of CIR
112
Corporate Any connections or communications
representative of between a server linked to the Trump
Stroz Freidberg Organization and Alfa server(s)
Bernard Sucher Relevant knowledge of Alfa, including 715 Sevilla Avenue, Coral
all entities affiliated with Alfa, Alfa’s ties Gables, FL 33134
21
to the Kremlin and Vladimir Putin, and

Alfa’s investments in U.S. companies;
roles in the business world
Lawrence Summers Communications with Plaintiffs; relations 207 Fisher Avenue
and communications between Plaintiffs Brookline, MA 02445
and US government officials; meetings
between Plaintiffs and US Government
Officials; Plaintiffs’ experience with
foreign policy; privatization of Russia
Vladislav Surkov Plaintiffs’ ties, communications,
them or acting on their behalf; events
related to topics in CIR 112; Russian
politics, elections, and/or policy; any
connections or communications between
a server linked to the Trump
Organization; Alfa’s ties to the Kremlin
and Vladimir Putin, on and Alfa server(s)
Marc Tessier- Relevant conduct of Plaintiffs and Alfa; President, Stanford

Lavigne Plaintiffs’ donations to charitable University
organizations and foundations Lasuen Mall Building 10,
Stanford, CA 94305
Representative of Relevant conduct of Plaintiffs, including 1901 N. Fort Myer Driver,

Trident Group, business roles, transactions, notoriety; Arlington VA 22209
LLC relevant conduct and transactions of Alfa;
Pranav L. Trivedi Plaintiffs’ communications, positions, Skadden Arps
and statements concerning U.S. politics; 40 Bank St, Canary Wharf,
U.S. non-profits and foundations; the London E14 5DS, UK
Organization; communications with the
Russian government
Representative of Plaintiffs’ communications, positions,

Trump and statements concerning U.S. politics; 725 Fifth Avenue New York,
Organization U.S. non-profits and foundations; the NY 10022
22

Russian government
Representative of Plaintiffs’ communications, positions,

2016 Trump and statements concerning U.S. politics;
Presidential U.S. non-profits and foundations; the
Campaign presidential election; the Trump
Russian government
Unknown PR Public relations activities of Plaintiffs;

representatives of Plaintiffs’ prominent roles in the business
Plaintiffs world; Plaintiffs’ interactions with the
media
Representative of Plaintiffs’ ties, communications, 1101 17th Street, NW

U.S.-Russia meetings, and relations with the Kremlin, Suite 600
Business Council Vladimir Putin, and those representing Washington DC 20036
non-profits and foundations
Anton Vaino Events related to topics in CIR 112;

on U.S policy; Plaintiffs’ investments in
the United States; Russian interference in
and/or influence on U.S. politics; Russian
interference in U.S. elections; Plaintiffs’
Corporate Defendants’ research and knowledge of
representative of Alfa and Plaintiffs
the Wall Street
Journal
Celeste Wallander Relevant conduct of Plaintiffs, Alfa;

Government’s receipt, delivery, and
in U.S. politics, elections, and policy;
Russian interference in U.S. elections;
23

on U.S policy; Russian interference in
and/or influence on U.S. politics
Matthias Warnig Relevant conduct of Plaintiffs, including
Plaintiffs’ relationships with the
Kremlin/Putin
Andrew Weissman Relevant conduct of Plaintiffs, including
Eric J. Wendel Relevant conduct of Plaintiffs, including Kirkland & Ellis LLP, 601
Jonathan Winer Delivery and receipt of CIR 112;
privileged publication
Andrej Wolf Delivery and receipt of CIR 112; Kirkland & Ellis LLP, 30 St
privileged publication Mary Axe, London, EC3A
8AF, United Kingdom
Curtis Wolfe Plaintiffs’ investments in the U.S.; Shutts & Bowen LLP, 200 S
Plaintiffs’ roles in the business world; Biscayne Blvd Ste 4100
Plaintiffs’ control of Alfa Miami, FL 33131-2362
Sir Andrew Wood Receipt and delivery of CIR 112
Bob Wood Plaintiffs’ lobbying efforts in the U.S. BGR Group, 601 13th St
Representative of Relevant conduct of Petr Aven; Aven’s Office of the President
Yale University’s communications, positions, and Yale University
President’s Council statements concerning U.S. politics; U.S. 3 Prospect Street, New
on International non-profits and foundations; the Haven, CT 06511
Activities presidential election; the Trump
States
24
Rabbi Hirschy Plaintiffs contacts with Chabad House; Chabad House at Harvard
Zarchi Plaintiffs’ donations to charitable 38 Banks Street
organizations and foundations Cambridge, Massachusetts
02138
Ilya Zaslavsky Plaintiffs’ roles in the business world;

them or acting on their behalf; Alfa,
including entities affiliated with Alfa;
Putin; Alfa’s investments in U.S.
companies; research related to matters in
CIR 112
Mike Zoi Plaintiffs’ investments in the U.S.; 3363 NE 163rd Street, Suite
Plaintiffs’ roles in the business world; 705, North Miami Beach,
Plaintiffs’ control of Alfa FL 33160
Debra L. Zumwalt Relevant conduct of Plaintiffs and Alfa; Vice President and General
Plaintiffs’ donations to charitable Counsel
organizations and foundations Building 170, Main Quad,
Stanford, CA 94305
Alex Van der Relevant conduct of German Khan; Flat 1, 16 St. Stephens
Zwaan German Khan’s role in the business Gardens, London W2 5QX
world; German Khan’s relationship with
Skadden Arps.
2. Description of Documents
The following list sets forth the documents in Defendants’ possession, custody, or control
that Defendants may use to support their defenses and/or counterclaim:
a. Electronically stored documents and e-mail messages on Fusion GPS’s system
b. Personal records of Glenn Simpson
3. Computation of Damages
25
Defendants deny liability for damages. As damages for their counterclaim, Defendants seek
their litigation costs including reasonable attorney’s fees pursuant to D.C. Code § 16-5504.
4. Insurance
None.
Dated: May 18, 2020
/s/ Joshua A. Levy

Joshua A. Levy (D.C. Bar No. 475108)
Rachel M. Clattenburg (D.C. Bar No. 1018164)
LEVY FIRESTONE MUSE LLP
Tel: (202) 845-3215
Fax: (202) 595-8253
jal@cunninghamlevy.com
rmc@cunninghamlevy.com
Counsel for Defendants
26
I HEREBY CERTIFY that on May 18, 2020, the foregoing Revised Rule 26(a)(1) initial
disclosures were e-mailed to counsel of record.
/s/ Joshua A. Levy

Joshua A. Levy
27
EXHIBIT D
REDACTED FOR PUBLIC RELEASE
Office of the Inspector General

U.S. Department of Justice
OVERSIGHT INTEGRITY GUIDANCE
Review of Four FISA Applications and

Other Aspects of the FBI’s Crossfire
Hurricane Investigation
Oversight and Review Division 20-012 December 2019 (Revised)
REDACTED FOR PUBLIC RELEASE

the FBI in November and December 2016 by a journalist, Senator John McCain, and
Ohr. When we asked Steele why he failed to provide all of his then-existing reports
to the FBI, he could not provide us with an explanation and said that he should
have given them to the FBI at the time.
E. Steele Discusses His Reporting with Third Parties in Late

September 2016 and the Yahoo News Article
During late September 2016, with Fusion GPS's authorization, Steele met
with numerous persons outside the FBI to discuss the intelligence he had obtained,
as part of his paid work for Fusion GPS, concerning Russian interference with the
2016 U.S. elections and allegations regarding the Trump campaign and candidate
Trump. 232 For example, as we discuss in Chapter Nine, emails exchanged between
Steele and Ohr show that Steele visited Washington, D.C., beginning around
September 21, 2016, and met with Ohr on September 23, at which time the two
discussed multiple issues involving election related intelligence that Steele had
collected. Steele told us that during this visit he also met with an attorney from
Perkins Coie, who was general counsel to the Clinton campaign. 233
Steele also met with journalists during his September trip to Washington,
D.C. According to a filing that Steele made in 2017 in foreign litigation, at Fusion
GPS's instruction, he briefed reporters from The New York Times, The Washington
information against Trump given how cooperative his team had been over several
years and of late);
• Report 105 (during a secret meeting between Putin and ex-Ukrainian President
Yanukovych, Yanukovych confided to Putin that he did authorize and order substantial
kick-back payments to Manafort but reassured Putin that no documentary trail was left
behind; Putin and Russian leadership were skeptical of the ex-President's assurances
that there were no traces of the payments; Manafort's departure from the Trump
campaign was attributable to Ukrainian corruption revelations as well as infighting with
campaign advisors);
• Report 112 (the leading figures of the Alpha group of businesses led by three Russian
oligarchs are on very good terms with Putin; Alpha held compromising information on
Putin and his corrupt business activities from the 1990s); and
• Report 113 (sources based in St. Petersburg reported that Trump has paid bribes and
engaged in sexual activities in St. Petersburg, including participating in sex parties,
but that witnesses had been "silenced," i.e., bribed or coerced to disappear).
232 This was not the first time that information included in Steele's reports concerning the
Trump campaign was known to individuals outside the FBI. For example, Handling Agent 1 emailed an
FBI supervisor on July 28, 2016, explaining that Steele had advised him that information from Reports
80 and 94 "may already be circulating at a 'high level' in Washington, D.C." Two days earlier,
according to a text between Carter Page and a Wall Street Journal reporter (that Page has since made
public), the reporter contacted Page inquiring whether Page had met with Sechin and Divyekin. The
FBI also received correspondence from Members of Congress in August 2016 that described
information included in the Steele reports. Additionally, then Assistant Secretary of State for
European and Eurasian Affairs Victoria Nuland publicly stated during an interview in 2018 that Steele's
election reporting was first provided to the State Department in July 2016.
233 Steele told us that he had a second meeting with this attorney in October 2016, and that
he had met with another attorney from Perkins Coie in July 2016.
104
Post, Yahoo News, The New Yorker, and CNN. The filing states that the briefings
were verbal, occurred at the end of September, and "involved the disclosure of
limited intelligence regarding indications of Russian interference with the U.S.
election process and the possible coordination of members of Trump's campaign
team and Russian government officials."
Steele told us that the press briefings were taskings from his client, Fusion
GPS, that his firm had to honor, and Simpson has testified that Simpson attended
the briefings. 234 Steele said that they were "off-the-record" and, while he made
mention of the reports, Steele did not distribute them to the journalists. Steele
explained that he discussed "general themes" from his reporting that lacked
sufficient specificity to identify his sources, and that he avoided answering
questions about whether he had reported his findings to authorities. 235
We asked Steele whether he believed his participation in the press briefings

was contrary to any admonishments that he had received previously from Handling
Agent 1. He said that he did not recall the FBI telling him he could not talk to
journalists about work that he performed on behalf of his firm's clients. According
to Steele, the election reporting was a "Pipeline 1" assignment and therefore the
FBI did not have a role in setting terms for his interactions with third parties, such
as news organizations. He said that if the FBI had tried to interfere in his
assignment for Fusion GPS, he would have objected and that such an attempt
would have been a "showstopper." Steele stated that Orbis' client for the election
reporting was Fusion GPS, which controlled and directed the terms for interactions
with third parties.
Handling Agent 1 told us that he understood why Steele would believe in

September 2016 that he did not have an obligation to discuss his press contacts
with him given that: (1) Steele's work resulted from a private client engagement;
and (2) Handling Agent 1 told Steele on July 5 that he was not collecting his
election reporting on behalf of the FBI. However, Handling Agent 1's view was that
while it was obvious that Fusion GPS would want to publicize Steele's election
information, it was not apparent that Steele would be conducting press briefings
and otherwise interjecting himself into the media spotlight. Handling Agent 1 told
us that he would have recommended that Steele be closed in September 2016 if he
had known about the attention that Steele was attracting to himself. According to
Handling Agent 1, Steele should have had the foresight to recognize this fact and
the professionalism to afford Handling Agent 1 an opportunity to assess the
situation. However, we are unaware of any FBI admonishments that Steele
violated by speaking to third parties, including the press, about work that he had
234 Simpson Senate Testimony, at 207.

235 According to a book co-authored by a Yahoo News reporter who was present for a Steele
September 2016 press briefing, Steele told him at the meeting that he had provided his election
reporting to the FBI and that there were "people in the [FBI] taking this very seriously." See Russian
Roulette: The Inside Story of Putin~ War on America and the Election of Donald Trump (New York:
Grand Central Publishing, 2018), 226.
105
Trump and was an "open secret" in Putin's government; (2) sex videos existed of
Trump; and (3) the FSB funneled payments to Trump through an Azerbaijani
family. According to Steele's notation to the report, Steele did not have a way to
verify the source(s) or the information but noted that, even though the reporting
originated from a different source network, some of it was "remarkably similar" to
Steele's reporting, especially with regard to the alleged 2013 Ritz Carlton incident
involving Trump and prostitutes, Trump's compromise by the FSB, and the
Kremlin's funding of the Trump campaign by way of the Azerbaijani family. The
Supervisory Intel Analyst characterized the report as "yet another report that would
need to be evaluated."
In addition to continuing to provide reporting to the FBI, Steele also was,

unbeknownst to the FBI at the time, continuing his outreach to the media
concerning alleged contacts between the Trump campaign and the Russian
government. According to information from the foreign litigation noted above,
Steele returned to Washington, D.C., in mid-October and provided additional
briefings to The New York Times, The Washington Post, and Yahoo News. We
asked Steele why he did not advise the FBI of his engagements with the media. He
stated that he did not alert the FBI because the media briefings were part of his
contract with Fusion GPS and were set up and attended by Simpson. As noted
above, Steele did not believe that the FBI had raised the issue of media contacts
with him at the early October meeting, and his contemporaneous notes from that
meeting do not mention the issue.
Further, Steele met on October 11 at the State Department with Winer and
Deputy Assistant Secretary Kathleen Kavalec, who was a deputy to then Assistant
Secretary Victoria Nuland. Steele told us that Winer had originally contacted him to
request that he meet with Nuland, who ultimately did not attend. 255 Notes of the
meeting taken by State Department staff reflect that Steele addressed a wide array
of topics during the meeting, including:
• Derogatory information on Trump;

• Manafort's role as a "go-between" with the campaign and Kremlin;
• The role of Alfa Bank, one of Russia's largest privately owned banks,
as a conduit for secret communications between Manafort and the
Kremlin;
• Manafort's debts to the Russians;
• Carter Page's meeting with Sechin;
• The Russian Embassy's management of a network of Russian emigres
in the United States who carry out hacking and recruiting operations;
and
255 Steele told us that he was delayed from the airport and arrived late for the meeting, by
which time Nuland had departed.
117
FBI liaison told us that he received no directives from the Crossfire Hurricane team
to gather information from Kavalec regarding her contact with Steele.
In anticipation of an FBI interview, Kavalec said she prepared a typewritten

summary of the meeting within 1 to 2 weeks after talking with the liaison. The
typed summary began by noting that Steele said at the meeting that he had
undertaken the investigation "at the behest of an institution he declined to identify
that had been hacked." The summary also noted that Steele told the attendees
that the "institution .. .is keen to see this information come to light prior to November
8." However, the FBI did not interview Kavalec nor did they seek her notes.
Two days after the meeting with Steele, Kavalec emailed an FBI CD Section
Chief a document that Kavalec received from Winer discussing allegations about a
linkage between Alfa Bank and the Trump campaign, a topic that was discussed at
the October 11 meeting. 259 Kavalec advised the FBI Section Chief in the email that
the information related to an investigation that Steele's firm had been conducting.
The Section Chief forwarded the document to SSA 1 the same day.
We asked Steele why he did not inform the FBI of the meeting at the State
Department and why he did not abide by the FBl's request for exclusivity. He said
he did not think it was appropriate to turn down a meeting request from an
Assistant Secretary of State, which he said he received on short notice. He also
stated that, at the time he received the meeting request, the meeting agenda was
unclear, and he was uncertain what topics he would be asked to discuss. He said it
was his understanding that the FBI did not object to his discussing general themes
with other agencies as opposed to "details" about his intelligence and source
network.
Handling Agent 1 told us that he believed Steele should have alerted him to
both his media contacts in September and October and his meeting with State
Department staff in October. As noted above, the Crossfire Hurricane team first
learned of Steele's October meeting with the State Department from the FBI liaison
on November 18, by which date the FBI had already closed Steele as a CHS
because of his Mother Jones disclosure, which we discuss in Chapter Six. Handling
Agent 1 explained that Steele should have recognized the need to provide this
notice to the FBI, especially given the discussions that took place with the Crossfire
Hurricane team in early October.
259 Steele separately wrote in Report 112, dated September 14, 2016, that Alfa Bank
allegedly had close ties to Putin. The Crossfire Hurricane team received Report 112 on or about
November 6, 2016, from a Mother Jones journalist through then FBI General Counsel James Baker.
Additionally, Ohr advised the FBI on November 21, 2016, according to an FBI FD-302, that Steele had
told Ohr that the Alfa Bank server was a link to the Trump campaign and that Person 1's
Russia/American organization in the U.S. had used the Alfa Bank server two weeks prior. Steele told
us that the information about Alfa Bank was not generated by Orbis. The FBI investigated whether
there were cyber links between the Trump Organization and Alfa Bank, but had concluded by early
February 2017 that there were no such links. The Supervisory Intel Analyst told us that he factored
the Alfa Bank/Trump server allegations into his assessment of Steele's reporting.
119
Hurricane team: "If the reporting is being made by a primary source, but based on
sub-sources, why is it reliable-even though second/third hand?" The OIG did not
find a written response to this specific question, and the OI Attorney did not recall a
response. However, the OI Attorney told us that the Crossfire Hurricane team
eventually briefed him on the sub-source information they learned from Steele after
their early October meeting with him (described in Chapter Four). He also received
a written summary of this information that the Supervisory Intel Analyst prepared
shortly after the October meeting. The OI Attorney told us that based on the
information the FBI provided, he thought at the time that some of the sub-sources
were "definitely" in a position to have had access to the information Steele was
reporting.
Ultimately, the initial drafts provided to OI management, the read copy, and
the final application submitted to the FISC contained a description of the source
network that included the fact that Steele relied upon a Primary Sub-source who
used a network of sub-sources, and that neither Steele nor the Primary Sub-source
had direct access to the information being reported. The drafts, read copy, and
final application also contained a separate footnote on each sub-source with a brief
description of his/her position or access to the information he/she was reporting.
The Supervisory Intel Analyst assisted the case agent in providing information on
the sub-sources and reviewed the footnotes for accuracy. According to the OI
Attorney, the application contained more information about the sources than is
typically provided to the court in FISA applications. According to Evans, the idea
was to present the source network to the court so that the court would have as
much information as possible.
B. Review and Approval Process
As described in Chapter Two, once an FBI case agent affirms the accuracy of
the information in the read copy of an application, an OI Unit Chief or Deputy Unit
Chief is usually the final and only approver before a read copy is submitted to the
FISC. The Unit Chief or Deputy is also usually the final approver that "signs out"
the final application ( cert copy) to the FBI for completion of the Woods Procedures
and Director's certification before presentation to either the Assistant Attorney
General (AAG) of NSD, the DAG, or Attorney General for final signature. The final
signatory receives an oral briefing, the cert copy, and a cover memorandum ( cert
memo) describing each application. In most cases, the start of the oral briefing, or
shortly beforehand, is the first time the application is presented to the final
signatory. According to NSD, most FISA applications do not get singled out for
additional review and, to place that in perspective, there are approximately 1,300
applications submitted to the FISC each year and roughly 25-40 final applications
go to the AAG, DAG, or the Attorney General for signature in any given week.
However, in some cases, according to NSD, a FISA application will receive

additional review and scrutiny, particularly if it presents a novel or complicated
issue or otherwise has been flagged for further review. In this case, as described
immediately below, documents and witness testimony reflect that the first Carter
Page FISA application underwent a lengthy review and editing process within NSD,
the FBI, and ODAG. According to Evans and other witnesses, this application had
133
and Case Agent 1 told us they did not recall any discussions about changing the
FBI's assessment in the FISA application concerning the Yahoo News disclosure
after learning Steele was responsible for the disclosure to Mother Jones. On
December 19, 2016, Case Agent 1 interviewed then FBI General Counsel James
Baker regarding his interacti ons with a Mother Jones reporter and Baker told Case
Agent 1 that the reporter advised Baker that a former intelligence official "was
passing information 'around town'" about Trump. Case Agent 1 said that by this
time, the team had also heard rumors that Steele's reporting had been "floated
around," so it was not clear to them who made the Yahoo News disclosure.
Further, we were told that, after the FBI closed Steele as a CHS, the team was not
going to have further communications with Steele.
II. The FBI Receives Additional Steel e Reporting Post-Election
Following the November 2016 U.S. elections, several third parties provided
the FBI with additional Steele election reporting, which the FBI included in its
validation efforts. Baker told the OIG that a Mother Jones reporter contacted him
and furnished him with nine reports from Steele, four of which Steele had not
previously provi ded to the FBI. 317 As described above, Baker was interviewed by
Case Agent 1 and Baker's discussion with the Mother Jones reporter was
documented in an FBI FD-302 report. According to the FD-302, Baker received a
collection of Steele's reports from the Mother Jones reporter, which Baker
forwarded to Priestap for analysis. 318
Several weeks later, on December 9, 2016, Senator John McCain provided

Comey with a collection of 16 Steele election reports, 5 of which Steele had not
given the FBI. 319 McCain had obtained these reports from a staff member at the
McCai n Institute. The McCain Institute staff member had met with Steele and later
acquired the reports from Simpson. Steele told the OIG that a former European
Ambassador to Russia who generally was familiar with Steele's election reporting
informed Steele that the former Ambassador would be meeting with Senator
McCain at a conference in Nova Scotia in November, and asked Steele whether he
wanted the former Ambassador to talk with McCain about the electi on reporting.
Steele said he replied that he did, which resulted in the McCain Institute staff
member visiting Steele in Europe in late November. Accordi ng to deposition
testimony the McCain Institute staff member provided in foreign litigation, during
317 The nine Steele reports were Reports 80, 94, 95, 97, 105, 111, 112, 134, and 136. The
FBI had not previously obtained Reports 97, 105, and 112 from Steele. According to an FBI FD-302,
in a conversation later that month, the Mother Jones reporter advised Baker that the Steele reports
also had been furnished to two Members of Congress, and that Steele was surprised that his reporting
had not received more attention in the media.
318 The Mother Jones reporter has stated publicly that he provided Steele reports to Baker.
See "A New Right-Wing Smear Campaign Targets a Former FBI Official to Distract From Russia
Scandal," Mother Jones, www .mothenones.com/politics/2019/01/a-new-riqht-winq-smear-campaiqn
tarqets-a-former-fbi-official-to-distract-from-russia-scandal/ (accessed November 22, 2019).
319 These were Steele Reports 80, 86, 94, 95, 97, 100, 101, 102, 105, 111, 112, 113, 130,
134, 135, and 136. FBI records show that the FBI had not previously received Reports 86, 97, 105,
112 and 113 from Steele.
175
allegations, and that it would not be appropriate to characterize all of the factual
information in the Steele election reporting as "uncorroborated."333
Lastl , the validation re ort included a recommendation that
Source reporting must accurately describe the reliability of

the information or its origin.
C. The FBI Identifies and Interviews the Primary Sub-Source in

Early 2017
An important aspect of the FBI's assessment of Steele's election reporting

involved evaluating Steele's source network, especially whether the sub-sources
had access to reliable information. As noted in the first FISA application, Steele
relied on a primary sub-source (Primary Sub-source) for information, and this
Primary Sub-source used a network of sub-sources to gather the information that
was relayed to Steele; Steele himself was not the originating source of any of the
factual information in his reporting. 334 The FBI employed multiple methods in an
effort to ascertain the identities of the sub-sources within the network, including
meeting with Steele in October 2016 (prior to him being closed for cause) and
conducting various investigative inquiries. For example, the FBI determined it was
plausible that at least some of the sub-sources had access to intelligence pertinent
to events described in Steele's election reporting. Additionally, the FBI's evaluation
of Steele's sub-sources generated some corroboration for the election reporting
(primarily routine facts about dates, locations, and occupational positions that was
mostly public source information). Further, by January 2017 the FBI was able to
identify and arrange a meeting with the Primary Sub-source. 335
The FBI conducted interviews of the Primary Sub-source in January, March,

and May 2017 that raised significant questions about the reliability of the Steele
election reporting. In particular, the FBI's interview with Steele's Primary Sub-
source in January 2017, shortly after the FBI filed the Carter Page FISA Renewal
333 We discuss the FBI's conclusions about the reporting in Section V of this chapter.
335 Steele did not disclose the identity of the Primary Sub-source to the FBI.
186
Application No. 1 and months prior to Renewal Application No. 2, ra ised doubts
about the reliability of Steele's descriptions of information in his election reports.
During the FBI's January interview, at which Case Agent 1, the Supervisory Intel
Analyst, and representatives of NSD were present, the Primary Sub-source told the
FBI that he/she had not seen Steele's reports until they became public that month,
and that he/she made statements indicating that Steele misstated or exaggerated
the Primary Sub-source's statements in multiple sections of the reporting. 336 For
example, the Primary Sub-source told the FBI that, whi le Report 80 stated that
Trump's alleged sexual activities at the Ritz Carlton hotel in Moscow had been
"confirmed" by a senior, western staff member at the hotel, the Primary Sub-source
explained that he/she reported to Steele that Trump's alleged unorthodox sexual
activity at the Ritz Carlton hotel was "rumor and speculation" and that he/she had
not been able to confirm the story. A second example provided by the Primary
Sub-source was Report 134's description of a meeting allegedly held between
Carter Page and Igor Sechin, the President of Rosneft, a Russian energy
conglomerate. 337 Report 134 stated that, according to a "close associate" of
Sechin, Sechin offered "PAGE/ TRUMP's associates the brokerage of up to a 19
percent (privatized) stake in Rosneft" in return for the lifting of sanctions against
the company. 338 The Prima ry Sub-source told the FBI that one of his/her sub-
sources furnished information for that part of Report 134 through a text message,
but said that the sub-source never stated that Sechin had offered a brokerage
interest to Page. 339 We reviewed the texts and did not find any discussion of a
bribe, whether as an interest in Rosneft itself or a "brokerage. " 340
336 David Laufman, then Chief of NSD's Counterintell igence and Export Control Section (CES),
covered the first portion of the January interview and his Deputy Section Chief covered the remaining
portions of the January interview. Laufman told us that he negotiated with the Primary Sub-source's
counsel to facilitate the FBI's interview and sought to "build a cooperative relationship that
could ...result in the Bureau's being in a position to assess the validity of information in the [Steele
election reporting] resulting from [the Primary Sub-source's] activities or the collection of [his/her]
sub-subsources. So I saw my role as a broker to get that re lationship consolidated ." Laufman said
that the portion of the interview he attended established the line of communication with the Primary
Sub-source and, as he recalled, generally covered the facts in a "superficial" way. He said that after
the completion of the interview, he never saw the FBI's written summary of the interview.
337
According to the Supervisory Intel Analyst, the FBI was not able to prove or disprove
Page's meeting with Sechin. The Ana lyst explained that Page did meet with a Rosneft official- Andrey
Baranov, during his July 2016 trip to Moscow and that Page told the FBI that Baranov might have
mentioned the possible sale of a stake in Rosneft. The Analyst stated that Report 134's mention of
Sechin cou ld be a "garble" for Baranov.
338 Report 134 contained differing information on the alleged bribe offered by Sechin to Page.
The Report first stated that Sechin offered Page a " large stake in Rosneft in return for lifting sanctions
on Russia." Later, the same report stated that Sechin had offered Page a much smaller sum of
money, "the brokerage of up to a 19 per cent (privatized) stake in Rosneft."
339The Primary Sub-source also told the FBI at these interviews that the sub-source who
rovided the information about t he Carter Pa e-Sechin meetin
340 According to a press report prior to the date of Report 134, a 19 -percent stake in Rosneft
could have sold for more than $ 10 billion. See https ://www .cnbc.com/2016/06/08/russias-oil-qiant-
187
The Primary Sub-source was questioned again by the FBI beginning in March
2017 about the election reporting and his/her communications with Steele. The
Washington Field Office agent (WFO Agent 1) who conducted that interview and
others after it told the OIG that the Primary Sub-source felt that the tenor of
Steele's reports was far more "conclusive" than was justified. The Primary Sub-
source also stated that he/she never expected Steele to put the Primary Sub-
source's statements in reports or present them as facts. According to WFO Agent
1, the Primary Sub-source said he/she made it clear to Steele that he/she had no
proof to support the statements from his/her sub-sources and that "it was just
talk. " WFO Agent 1 said that the Primary Sub-source explained that his/her
information came from "word of mouth and hearsay; " "conversation that [he/she]
had with friends over beers;" and that some of the information, such as allegations
about Trump's sexual activities, were statements he/she heard made in "jest."341
The Primary Sub-source also told WFO Agent 1 that he/she believed that the other
sub-sources exaggerated their access to information and the relevance of that
information to his/her requests. The Primary Sub-source told WFO Agent 1 that
he/she "takes what [sub-sources] tell [him/her] with 'a grain of salt."'
In addition, the FBI interviews with the Primary Sub-source revealed that
Steele did not have good insight into how many degrees of separation existed
between the Primary Sub-source's sub-sources and the persons quoted in the
reporting, and that it could have been multiple layers of hearsay upon hearsay. For
example, the Primary Sub-source stated to WFO Agent 1 that, in contrast to the
impression left from the election reports, his/her sub-sources did not have direct
access to the persons they were reporting on. Instead, the Primary Sub-source told
WFO Agent 1 that their information was "from someone else who may have had
access."
The Primary Sub-source also informed WFO Agent 1 that Steele tasked
him/her after the 2016 U.S. elections to find corroboration for the election reporting
and that the Primary Sub-source could find none. According to WFO Agent 1,
during an interview in May 2017, the Primary Sub-source said the corroboration
was "zero." The Primary Sub-source had reported the same conclusion to the
Crossfire Hurricane team members who interviewed him/ her in January 2017.
Following the January interview with the Primary Sub-source, on February

15, 2017, Strzok forwarded by email to Priestap and others a news article
referencing the Steele election reporting; Strzok commented that "recent interviews
and investigation, however, reveal [Steele] may not be in a position to judge the
reliability of his sub-source network. " According to the Supervisory Intel Analyst,
the cause for the discrepancies between the election reporting and explanations
iust-saw-its-profits-drop-75.html (accessed Dec. 8, 2019). We discuss below the issue of Steele or

the sub-sources presenting their analyses as statements of Kremlin officials or others.
341 According to WFO Agent 1, the Primary Sub-source told him that he/she spoke with at
least one staff member at the Ritz Carlton hotel in Moscow who said that there were stories
concerning Trump's alleged sexual activities, not that the activities themselves had been confirmed by
the staff member as stated in Report 80.
188
In addition to the lack of corroboration, we found that the FBI's interviews of

Steele, the Primary Sub-source, and a second sub-source, and other investigative
activity, revealed potentially serious problems with Steele's description of
information in his election reports. For example, as noted above, the Primary Sub
source's accounting of events during his/her January 2017 interview with the FBI
(after the filing of the first FISA application and Renewal Application No. 1, but
before the filing of Renewal Application No. 2) was not consistent with and, in fact,
contradicted the allegations in Reports 95 and 102 attributed to Person 1, as well as
those in Report 94 concerning the meeting between Page and Sechin. In addition,
another sub-source told the FBI in August 2017 (after the filing of Renewal
Application No. 3) that information in Steele's election reporting attributable to
him/her had been "exaggerated." Because the sub-sources themselves could have
furnished exaggerated or false information to Steele, as well as to the FBI during
their interviews, the cause of these inconsistencies remains unknown. According to
the Supervisory Intel Analyst, the FBI ultimately determined that some of the
allegations contained in Steele's election reporting were inaccurate, such as the
allegation that Manafort used Page as an intermediary (Report 95) and that Michael
Cohen had travelled to Prague for meetings with representatives of the Kremlin
(Reports 134, 135, 136, and 166). Although the Supervisory Intel Analyst also
stated that some of the broader themes in Steele's election reporting were
consistent with USIC assessments, such as Russia's desire to sow discord in the
Western Alliance, he further told us that, as of September 2017, the FBI had
corroborated limited information in the Steele election reporting, and much of that
information was publicly available.507
As we described earlier in our analysis, the FBI failed to notify 01, which was
working on the Carter Page FISA applications, of the potentially serious problems
identified with Steele's election reporting that arose as early as January 2017
through the efforts described above. As previously stated, we believe it was the
obligation of the agents who were aware of this information to ensure that OI and
the decision makers had the opportunity to consider it, both for their own
assessment of probable cause and for consideration of whether to include the
information in the applications so that the FISC received a complete and accurate
recitation of the relevant facts. Moreover, even as the FBI developed this
507 As discussed in detail in Chapter Six, FBI leadership, including Comey and McCabe,
advocated for the Steele election reporting to be included in the Intelligence Community Assessment
(ICA) on Russian election interference that was being prepared in December 2016. For example, in a
December 17 telephone call with the Director of National Intelligence (DNI), Comey stated that the FBI
was "proceeding cautiously to understand and attempt to verify the reporting as best we can, but we
thought it important to bring it forward to the IC effort." However, according to the Intel Section
Chief and Supervisory Intel Analyst, as the interagency editing process for the ICA progressed, the
CIA expressed concern about using the Steele election reporting in the body of the ICA, and
recommended that it be moved to an appendix. In a December 28, 2016 email to the Office of the
Director of National Intelligence (ODNI) Principal Deputy Director, McCabe objected to this
recommendation, stating, "We oppose CIA's current plan to include [the election reporting] as an
appendix." However, the FBI Intel Section Chief told us that the CIA viewed the Steele reporting as
"internet rumor." The FBI's view did not prevail, and the final ICA report included a short summary of
the Steele election reporting in an appendix.
384
EXHIBIT E
7/20/2020 CaseCommittee
Judiciary 1:17-cv-02041-RJL
Releases Declassified Document
Documents that 90-2 Filed
Substantially 08/04/20
Undercut Page
Steele Dossier, 95FISA
Page of Warrants
191 | United States …
JULY 17, 2020
Judiciary Committee Releases Declassified

Documents that Substantially Undercut Steele
Dossier, Page FISA Warrants
WASHINGTON – Today, as part of the Senate Judiciary Committee’s ongoing
investigation into the Crossfire Hurricane investigation and related FISA abuses,
Chairman Lindsey Graham (R- South Carolina) released two recently declassified
documents that significantly undercut the reliability of the Steele dossier and the
accuracy and reliability of many of the factual assertions in the Carter Page FISA
applications.
“I’m very pleased the investigation in the Senate Judiciary Committee has been
able to secure the declassification of these important documents,” said
Chairman Graham. “I want to thank Attorney General Barr for releasing these
documents and allowing the American People to judge for themselves.
“What have we learned from the release of these two documents by the
Department of Justice? Number one, it is clear to me that the memo regarding
the FBI interview of the primary sub-source in January 2017 should have
required the system to stop and reevaluate the case against Mr. Page.
“Most importantly after this interview of the sub-source and the subsequent
memo detailing the contents of the interview, it was a miscarriage of justice for
the FBI and the Department of Justice to continue to seek a FISA warrant
against Carter Page in April and June of 2017.
https://www.judiciary.senate.gov/press/rep/releases/judiciary-committee-releases-declassified-documents-that-substantially-undercut-steele-dossier-pa… 1/4
Undercut Page
Page of Warrants
“The dossier was a critical document to justify a FISA warrant against Mr. Page
and this DOJ memo clearly indicates that the reliability of the dossier was
completely destroyed after the interview with the primary sub-source in
January 2017. Those who knew or should have known of this development and
continued to pursue a FISA warrant against Mr. Page anyway are in deep legal
jeopardy in my view.
“Secondly, the comments of Peter Strzok regarding the February 14 New York
Times article are devastating in that they are an admission that there was no
reliable evidence that anyone from the Trump Campaign was working with
Russian Intelligence Agencies in any form.
“The statements by Mr. Strzok question the entire premise of the FBI’s
investigation of the Trump Campaign and make it even more outrageous that
the Mueller team continued this investigation for almost two and a half years.
Moreover, the statements by Strzok raise troubling questions as to whether the
FBI was impermissibly unmasking and analyzing intelligence gathered on U.S.
persons.
“These documents, which I have long sought, tell a damning story for anyone
who’s interested in trying to find the truth behind the corrupt nature of the
FBI’s investigation into the Trump campaign in 2016 and beyond.”
The first document is a 57-page summary of a three-day interview the FBI conducted
with Christopher Steele’s so-called “Primary Sub-source” in January of 2017.
[Document 1]
This document not only demonstrates how unsubstantiated and unreliable the
Steele dossier was, it shows that the FBI was on notice of the dossier’s
credibility problems and sought two more FISA application renewals after
gaining this awareness.
The document reveals that the primary “source” of Steele’s election reporting
was not some well-connected current or former Russian official, but a non-
Undercut Page
Page of Warrants
Russian based contract employee of Christopher Steele’s firm. Moreover, it
demonstrates that the information that Steele’s primary source provided him
was second and third-hand information and rumor at best.
Critically, the document shows that Steele’s “Primary Sub-source” disagreed
with and was surprised by how information he gave Steele was then conveyed
by Steele in the Steele dossier. For instance, the “Primary Sub-source”: did not
recall or did not know where some of the information attributed to him or his
sources came from; was never told about or never mentioned to Steele certain
information attributed to him or his sources; he said that Steele re-characterized
some of the information to make it more substantiated and less attenuated than
it really was; that he would have described his sources differently; and, that
Steele implied direct access to information where the access to information was
indirect.
In total, this document demonstrates that information from the Steele dossier,
which “played a central and essential role” in the FISA warrants on Carter Page,
should never have been presented to the FISA court.
The second document contains Peter Strzok’s type-written comments disagreeing

with assertions made in a New York Times article about alleged Russian intelligence
ties to the Trump campaign. [Document 2]
The document demonstrates that Peter Strzok and others in FBI leadership
positions must have been aware of the issues with the Steele dossier that the
FBI’s interview with Steele’s “Primary Sub-source” revealed, because Strzok
commented that “[r]ecent interviews and investigation, however, reveal Steele
may not be in a position to judge the reliability of his sub-source network.”
The document further shows that the FBI’s assertion to the FISA court that “the
FBI believes that Russia’s efforts to influence U.S. policy were likely being
coordinated between the RIS [Russian Intelligence Services] and Page, and
possibly others” appears to be a misrepresentation. This is because, in his
comments on the Times article, Strzok asserts that “[w]e have not seen
evidence of any individuals affiliated with the Trump team in contact with IOs
[Intelligence Officials]. . . . We are unaware of ANY Trump advisors engaging in
conversations with Russian intelligence officials.”
The document also indicates that the FBI may have been using foreign
intelligence gathering techniques to impermissibly unmask and analyze existing
and future intelligence collection regarding U.S. persons associated with the
Undercut Page
Page of Warrants
Trump campaign: “Both the CIA and NSA are aware of our subjects and
throughout the summer we provided them names and selectors for queries of
their holdings as well as prospective collection.” The quote does not provide
enough information to fully understand exactly what the FBI was doing but
impermissible unmasking and analysis of existing and future incidental
intelligence collection of U.S. persons would be troubling.
The document also raises questions as to whether the FBI was properly using
intelligence techniques and databases “throughout the summer” considering
that the earliest formal investigation of a U.S. person associated with the Trump
campaign was not officially opened until July 31, 2016.
These declassified documents and other related material may be accessed at the
following link: judiciary.senate.gov/fisa-investigation.
EXHIBIT F

MIKHAIL FRIDMAN, PETR AVEN, and

GERMAN KHAN,
Plaintiffs,
Civil Case No. 1:17-cv-2041-RJL
v.
BEAN LLC a/k/a FUSION GPS, and GLENN

SIMPSON,
Defendants.
DEFENDANTS’ REVISED ANSWERS TO PLAINTIFFS’ FIRST SET OF

INTERROGATORIES AND ANSWERS TO PLAINTIFFS’ SECOND SET OF
INTERROGATORIES
Defendants Bean LLC a/k/a Fusion GPS and Glenn Simpson hereby revise their response
to Plaintiffs’ first set of interrogatories, and answer Plaintiffs’ second set of interrogatories, as set
forth below.
(a) The information in these Answers is not based solely on the knowledge of the executing
party, but includes the knowledge of the executing party’s agents, representatives and attorneys
unless privileged.
(b) The word usage and sentence structure are those of the attorney and do not purport to
be the exact language of the executing party.
(c) The disclosure of any documents or information does not constitute an admission by
Defendants that such documents or information are relevant to the Action or admissible in
evidence.
1
ANSWERS
1. Other than litigation counsel of record in this Action, identify the individuals
who provided the answers to these Interrogatories or contributed information used in
answering these Interrogatories. If more than one person provided the answers or
information, identify each individual person, state whether he or she answered or
contributed information used in answering specific Interrogatories—identify those
Interrogatories, and explain specifically what information was contributed by each person
to each answer.
ANSWER: The following individuals contributed information to these Answers: Glenn

Simpson, Peter Fritsch, Jake Berkowitz, and Laura Seago.
2. With regard to the individuals you identified in Part 1 of your Initial

Disclosures, dated September 25, 2019, describe the specific subjects on which such
individuals are likely to have information relevant to the subject matter of this Action.
ANSWER: Objection. Defendants object because this Interrogatory is vague, overly

broad, and not proportional to the needs of the case, because it seeks information that is
not relevant to any party’s claim or defense in this action. Rule 26(b)(1) limits the scope of
discovery to matters that are “relevant to any party’s claim or defense and proportional to
the needs of the case,” whereas this Interrogatory seeks information “relevant to the subject
matter of this Action,” which is broader than the scope permitted by Rule 26(b)(1).
Defendants object to the term “you.” Plaintiffs’ definition of “you” includes “persons or
entities acting . . . in concert with” the Defendants, but information in the possession,
custody, or control of persons or entities acting “in concert with” the Defendants is not in
Defendants’ possession, custody, or control and the Defendants therefore cannot provide
that information. Defendants also object because this Interrogatory calls for a response that
is more suitable to a deposition. Additionally, Defendants are not aware of all subjects on
which these individuals are likely to have information.
With respect to the non-objectionable portion of the Interrogatory, Defendants, based on

what they know today, identify the following specific subjects on which the individuals
identified in Part 1 of their amended initial disclosures, dated May 18, 2020, are likely to
have information that is relevant to any party’s claim or defense:
Name Subject Matter
Glenn Simpson Full knowledge of dispute
Peter Fritsch Full knowledge of dispute
Jake Berkowitz Full knowledge of dispute
Jason Felch Full knowledge of dispute
Petr Aven Full knowledge of dispute
2
Mikhail Fridman Full knowledge of dispute
German Khan Full knowledge of dispute
Corporate representative All entities affiliated with Alfa; Alfa’s ties to the Kremlin and
of Alfa Group Vladimir Putin; Alfa’s investments in U.S. companies; Plaintiffs’
access to Alfa public relations staff; events related to topics in CIR
112; any connections or communications between a server linked to
the Trump Organization and Alfa server(s)
Alfa Fellowship Program Relevant conduct of Plaintiffs; Plaintiffs’ communications,

corporate representative positions, and statements concerning U.S. politics, U.S. non-profits
and foundations, the presidential election, the Trump Organization;
Plaintiffs’ wealth and notoriety; Plaintiffs’ interactions with the
media; Plaintiffs’ roles in the business world; Plaintiffs’ donations
to charitable organizations and foundations; Plaintiffs’ public
Representative of Plaintiffs’ roles in the business world; Plaintiffs’ access to public

Amsterdam Trade Bank relations staff; Plaintiffs’ communications and statements regarding
relationships with the Kremlin/Putin; Plaintiffs’ wealth and
notoriety
Corporate representative Relevant conduct of Plaintiffs; Plaintiffs’ roles in the business

of APCO world; Plaintiffs’ control of Alfa; Plaintiffs’ access to public
relations staff; Plaintiffs’ relationships with the Kremlin/Putin
Howard Ash Plaintiffs’ investments in the U.S.; Plaintiffs’ roles in the business
world; Plaintiffs’ control of Alfa
Anders Aslund Relevant conduct of Plaintiffs, including Plaintiffs’ investments in

the United States; Plaintiffs’ communications, positions, and
statements concerning U.S. politics, U.S. non-profits and
foundations, the presidential election, the Trump Organization;
Representative of Atlantic Relevant conduct of Plaintiffs; speeches by Plaintiffs at Atlantic

Council Council events; Plaintiffs’ meetings with US officials;
contributions by Plaintiffs to Atlantic Council; Plaintiffs as public
figures; Plaintiffs’ public relations activities in the United States;
3
Plaintiffs’ lobbying efforts in the United States and abroad;

relationship between Plaintiffs and Kremlin/Putin
James A. Baker III Plaintiffs’ notoriety; Plaintiffs’ communications, positions, and

foundations; Plaintiffs’ roles in the business world; Plaintiffs’
public relations activities in the United States
James Baker Relevant conduct of David Corn and Chris Steele; Recipients of
CIR 112; Research related to matters in CIR 112; events related to
topics in CIR 112; delivery of CIR 112; Russian interference in
and/or influence on U.S. policy and/or U.S. politics; Russian
interference in and/or influence on U.S. elections; FBI’s knowledge
of CIR 112; Government investigations into Russian interference in
U.S. politics, elections, and policy
Mike Baker Plaintiffs’ investments in the United States; Plaintiffs’ roles in the
business world; Plaintiffs’ interactions with the media; Plaintiffs’
involvement in Alfa dispute with IPOC; Plaintiffs’ public relations
Gov. Haley Barbour Plaintiffs’ lobbying efforts in the U.S. and abroad; Plaintiffs’
interactions with the media; Plaintiffs’ public relations activities in
the United States; Plaintiffs’ and Alfa’s roles in the business world
Edward Baumgartner Relevant conduct of Plaintiffs; Plaintiffs’ roles in the business

world; Plaintiffs’ ties, communications, meetings, and relations
acting on their behalf; Alfa, including entities affiliated with Alfa;
Alfa’s ties to the Kremlin and Vladimir Putin; Alfa’s investments
in U.S. companies; research related to matters in CIR 112
Ken Bensinger Relevant conduct of Buzzfeed; recipients of CIR 112; delivery of

CIR 112
Corporate representative Plaintiffs’ lobbying efforts in the U.S. and abroad; Plaintiffs’
of BGR interactions with the media; Plaintiffs’ public relations activities in
the United States
Jeffrey Birnbaum Plaintiffs’ lobbying efforts in the U.S. and abroad; Plaintiffs’
the United States
Sir Leonard Blavatnik Plaintiffs’ roles in the business world; Plaintiffs’ access to public
relations staff; Plaintiffs’ communications and statements regarding
relationships with the Kremlin/Putin; Plaintiffs’ wealth and
4
notoriety; Plaintiffs’ investments in the United States; Plaintiffs’

ties, communications, meetings, and relations with the Kremlin,
Vladimir Putin, and those representing them or acting on their
behalf; Plaintiffs’ accumulation of wealth
Corporate representative Relevant conduct of Plaintiffs, Alfa; Plaintiffs’ roles in the business
for BP world; events related to topics in CIR 112; Plaintiffs’ notoriety;
Plaintiffs’ relationships with the Kremlin/Putin
Christopher Brose recipients of CIR 112, delivery of CIR 112
Nicholas Burgess Plaintiffs’ roles in the business world; Plaintiffs’ control of Alfa
William J. Burns Plaintiffs’ interactions with the Carnegie Endowment for

International Peace; Plaintiffs’ relationship with the Kremlin/Putin
Chris Burrows Relevant conduct of Orbis and Christopher Steele; Christopher

Steele, including his experience, work, process, and engagement by
Defendants
Richard Burt Public relations and lobbying efforts of Plaintiffs in the US and
abroad; Plaintiffs’ visits to the White House and contacts with
White House officials; relevant conduct of Plaintiffs; Plaintiffs’
investments in the US; Plaintiffs’ interactions with the media;
Plaintiffs’ roles in the business world; Plaintiffs’ ties,
communications, meetings, and relations with the Kremlin,
behalf; Plaintiffs’ wealth and notoriety; Plaintiffs’ communications,
positions, and statements concerning U.S. politics, U.S. non-profits
and foundations, the presidential election, the Trump
Organization; Plaintiffs’ contacts with the Trump Organization, the
Trump Campaign, and the Trump
Administration; Russian interference in and/or influence on U.S
policy and/or in U.S. elections; Alfa’s relevant conduct, including
all entities affiliated with Alfa, Alfa’s ties to the Kremlin and
Vladimir Putin, and Alfa’s investments in U.S. companies
Fred Burton Relevant conduct of Plaintiffs and Alfa; Plaintiffs’ ties,

behalf
5
Groslyn Burton Plaintiffs’ visits to the White House and contacts with White House
officials
Jean Camp Relevant conduct of Alfa and the Plaintiffs concerning Alfa servers
Corporate representative Plaintiffs’ and Alfa’s interactions with Carnegie Endowment for
of Carnegie Endowment International Peace; Plaintiffs’ donations to charitable
for International Peace organizations and foundations
Charlie Carr Relevant conduct of Plaintiffs and Alfa; Plaintiffs’ and Alfa’s
relationship with the Kremlin/Putin; Plaintiffs as public figures
Representative of Center Plaintiffs’ ties, communications, meetings, and relations with the
for the National Interest Kremlin, Vladimir Putin, and those representing them or acting on
their behalf; Plaintiffs’ communications, positions, and statements
concerning U.S. politics; U.S. non-profits and foundations; the
presidential election; the Trump Organization; Government
investigations into Russian interference in U.S. politics, elections,
and policy
Representative of Chabad Plaintiffs contacts with Chabad House; Plaintiffs’ donations to

House at Harvard charitable organizations and foundations
Jim Cobery Plaintiffs’ donations to charitable organizations and foundations;

Plaintiffs’ involvement with the Genesis Prize Foundation
James Comey Relevant conduct of Plaintiffs, Alfa; FBI’s knowledge of CIR 112;
Government investigations into Russian interference in U.S.
politics, elections, and policy; Russian interference in U.S.
elections; Russian interference in and/or influence on U.S policy;
Russian interference in and/or influence on U.S. politics
Council on Foreign Plaintiffs’ donations to charitable organizations and foundations;

Relations Plaintiffs’ roles in the business world; Plaintiffs’ notoriety;
Plaintiffs’ communications, positions, and statements concerning
U.S. politics, US-Russian policy, U.S. non-profits and foundations;
Plaintiffs’ foreign policy experience
6
Jonathan Davis Relevant conduct of Plaintiffs, including business roles,

transactions, notoriety; relevant conduct and transactions of Alfa;
Representative of the U.S. Relevant conduct of Plaintiffs, Alfa; FBI’s knowledge of CIR 112;
Department of Justice Government investigations into Russian interference in U.S.
Dimitry Dikman Relevant conduct of Plaintiffs; Plaintiffs’ creation and involvement

in Genesis Philanthropy Group; Plaintiffs’ donations to charitable
organizations and foundations; Plaintiffs’ involvement with the
Genesis Prize Foundation
Jill Dougherty Relations between Plaintiffs and the media
Robert Dudley Relevant conduct of Plaintiffs, including business roles,

David Edwards Relevant conduct of Plaintiffs, including business roles,

Maria Faasen (née Putin) Relevant conduct of Plaintiffs and Alfa; Plaintiffs’ relations with
Vladimir Putin and family
Representative of the U.S. Relevant conduct of Plaintiffs, Alfa; FBI’s knowledge of CIR 112;
Federal Bureau of Government investigations into Russian interference in U.S.
Investigation politics, elections, and policy; Russian interference in U.S.
Jeffrey W. Ferguson Plaintiffs’ investment in the United States; publication of such

investment
Oleg Firer Plaintiffs’ investments in the U.S.; Plaintiffs as public figures;

Plaintiffs’ control of Alfa
Michael Froman Plaintiffs’ relationships with the Kremlin/Putin; Plaintiffs’

communications, positions, and statements regarding foreign
policy; Plaintiffs’ public relations and lobbying efforts in the U.S.
7
and abroad; Plaintiffs’ ties, communications, meetings, and

relations with the Kremlin, Vladimir Putin, and those representing
Mark Galeotti Plaintiffs’ relationship with the Kremlin/Putin; relationships

between Russian oligarchs and the Kremlin/Putin; influence of
Russian oligarchs on the Kremlin/Putin; corruption in Russia; the
privatisation of Russia
Toby Gati Relevant conduct of Plaintiffs, including Plaintiffs’ investments in

the United States; Plaintiffs’ communications, positions, and
foundations; Plaintiffs’ wealth and notoriety; Plaintiffs’ interactions
with the media; Plaintiffs as public figures; Plaintiffs’ public
relations activities in the United States; relationships between
Russian oligarchs and the Kremlin/Putin
Gennady Gazin Relevant conduct of Plaintiffs; Plaintiffs’ creation and involvement

Genesis Philanthropy Relevant conduct of Plaintiffs; Plaintiffs’ creation and involvement

Group corporate in Genesis Philanthropy Group; Plaintiffs’ donations to charitable
representative organizations and foundations; Plaintiffs’ involvement with the
Thomas W. Gilligan Relevant conduct of Plaintiffs and Alfa; Plaintiffs’ donations to

charitable organizations and foundations
Jose Grinda Gonzalez Investigations into alleged illegal transactions by Mikhail Fridman
Oleg Govorun Relevant conduct of Plaintiffs, Alfa, Putin, Kremlin; events related
to topics in CIR 112
David Grenker Relevant conduct of Plaintiffs, including business roles,

Steven Hall Relationship between Plaintiffs and Kremlin/Putin
John Halsted Relevant conduct of Mikhail Fridman; national security concerns

regarding investment by Mikhail Fridman
8
Andrew Hayes Public relations activities of Plaintiffs; Plaintiffs as public figures;

Fred Hiatt Plaintiffs’ relations with the media; communications with Plaintiffs
and their media representatives; knowledge of Plaintiffs’ media
representatives
David Higgins Relevant conduct of Plaintiffs, including business roles,

Representative of Public relations activities of Plaintiffs; Plaintiffs as public figures;

Hill+Knowlton Strategies Plaintiffs’ interactions with the media;
Daniel Hoffman Oligarchs and their ties to the Kremlin; relevant conduct of Alfa
and Plaintiffs; Plaintiffs’ ties, communications, meetings, and
Karl V. Hopkins Relevant conduct of Plaintiffs; speeches by Plaintiffs at Atlantic

Council events; Plaintiffs’ meetings with US officials;
Matthias Horbach Relevant conduct of Plaintiffs, including business roles,

events related to topics in CIR 112; Plaintiffs as public figures
Robert Hormats Meetings with Plaintiffs; communications and their representatives;

relationship between Plaintiffs and US government officials
Corporate representative Public relations activities of Plaintiffs; Plaintiffs as public figures;

of Hudson Sandler Plaintiffs’ interactions with the media;
David Ignatius Plaintiffs’ relations with the media; communications with Plaintiffs
and their media representatives; knowledge of Plaintiffs’ media
representatives; relationship between Plaintiffs and Kremlin/Putin
9
Andrey Illiaronov Relationship between Plaintiffs and Kremlin/Putin; Plaintiffs’

public appearances; Plaintiffs’ and Alfa’s business tactics;
Carl Jenkins Plaintiffs’ roles in the business world; Plaintiffs’ notoriety;

Plaintiffs’ business tactics; Plaintiffs’ dispute with IPOC
Ryan Junck Plaintiffs’ relationships with the Kremlin/Putin; Plaintiffs’

Adrian Karatnycky Lobbying on behalf of Plaintiffs and Alfa; Plaintiffs’ relations with
the media and US government officials; access to public relations
Kennan Institute Plaintiffs’ interactions with the media; Plaintiffs’ wealth and
Corporate Representative notoriety; Plaintiffs’ donations to charitable organizations and
foundations; Plaintiffs’ investments in the United States; Plaintiffs
as public figures; Plaintiffs’ public relations activities in the United
States; Plaintiffs’ lobbying efforts in the United States and abroad
Fred Kempe Relevant conduct of Plaintiffs; speeches by Plaintiffs at Atlantic

Council events; Plaintiffs’ meetings with US officials;
Alexa King Communications between Plaintiffs/Alfa and the Trump

Campaign/Trump Organization
Corporate representative Relevant conduct of Plaintiffs, including business roles,

of Kirkland & Ellis LLP transactions, notoriety; relevant conduct and transactions of Alfa;
Denis Klimentchenko Plaintiffs’ control of Alfa; TNK-BP transaction; Plaintiffs’

transactions and their relationship with the Kremlin/Putin; favors
exchanged between Putin and Plaintiffs
10
Alex Knaster Relevant conduct of Mikhail Fridman; national security concerns

regarding investment by Mikhail Fridman
Yuri Koshkin Relevant conduct of Plaintiffs and Alfa; Plaintiffs’ ties,

behalf
Robert Kraft Plaintiffs’ donations to charitable organizations and foundations;

Plaintiffs’ involvement with the Genesis Prize Foundation;
David Kramer Delivery and receipt of CIR 112; privileged publication
Corporate representative Plaintiffs’ roles in the business world; Plaintiffs’ notoriety;

of Kroll Plaintiffs’ business tactics; Plaintiffs’ dispute with IPOC;
Defendants’ background knowledge of Alfa and the Plaintiffs;
Plaintiffs’ and Alfa’s relationship with the Kremlin/Putin
Jeremy M. Kroll Plaintiffs’ roles in the business world; Plaintiffs’ notoriety;

Plaintiffs’ business tactics; Plaintiffs’ dispute with IPOC;
Jules B. Kroll Plaintiffs’ roles in the business world; Plaintiffs’ notoriety;

Plaintiffs’ business tactics; Plaintiffs’ dispute with IPOC;
Simon Kukes Plaintiffs’ roles in the business world; Plaintiffs’ notoriety;

Plaintiffs’ business tactics; Plaintiffs’ ties, communications,
meetings, and relations with the Kremlin, Vladimir Putin, and those
representing them or acting on their behalf
Josh Kushner Plaintiffs’ investments in the U.S.; Plaintiffs’ wealth and notoriety;
Plaintiffs’ roles in the business world
James C. Langdon Jr. Plaintiffs’ roles in the business world; Plaintiffs’ control of Alfa;
Plaintiffs’ business tactics
Amb. Ronald Lauder Plaintiffs’ donations to charitable organizations and foundations;

Plaintiffs’ public relations activities in the United States; Plaintiffs’
11
lobbying efforts in the United States and abroad; Plaintiffs’

interactions with the media
Vladimir Lechtman Relevant conduct of Plaintiffs regarding creation of LetterOne;

Plaintiffs’ control of Alfa
Eric Lichtblau Receipt and delivery of CIR 112
David Lipton Relevant conduct of Plaintiffs; Plaintiffs’ public relations activities

in the United States; Plaintiffs’ lobbying efforts in the United States
and abroad; Plaintiffs’ interactions with the media; Plaintiffs’ roles
in the business world
Mark MacDougall Plaintiffs’ relationship with the Kremlin; Plaintiffs’ notoriety;

Plaintiffs’ conduct regarding the IPOC dispute; Defendants’
knowledge of Plaintiffs; Plaintiffs’ use of Kroll
Maria Mammina Relevant conduct of Plaintiffs; Plaintiffs’ communications,

and foundations, the presidential election, the Trump Organization;
Kevin Mandia Any connections or communications between a server linked to the

Trump Organization and Alfa server(s)
Corporate representative Any connections or communications between a server linked to the

of Mandiant Trump Organization and Alfa server(s)
Peter Martelli Relevant conduct of Plaintiffs, including business roles,

Andrew McCabe Relevant conduct of Plaintiffs, Alfa; FBI’s knowledge of CIR 112;
12

Michael McFaul Plaintiffs’ relationships with the Kremlin/Putin; Plaintiffs’

Joy McGrath Relevant conduct of Petr Aven; Aven’s communications, positions,
and statements concerning U.S. politics, U.S. non-profits and
Aven’s wealth and notoriety; Aven’s donations to charitable
organizations and foundations; Plaintiffs’ public relations activities
in the United States
Corporate representative Public relations and lobbying efforts of Plaintiffs in the US and
of McLarty Associates abroad; Plaintiffs’ visits to the White House and contacts with
Ed Mermelstein Public relations and lobbying efforts of Plaintiffs in the US and

abroad; Plaintiffs’ investments in the US; Plaintiffs’ interactions
with the media; Plaintiffs’ roles in the business world;
U.S. politics, U.S. non-profits and foundations, the presidential
election, the Trump
Organization; Alfa’s relevant conduct, including all entities
affiliated with Alfa, Alfa’s ties to the Kremlin and Vladimir Putin,
and Alfa’s investments in U.S. companies
Clark R. Moore Plaintiffs as public figures; Plaintiffs’ notoriety; Plaintiffs’ business
tactics; Plaintiffs’ ties, communications, meetings, and relations
13

Alejandro Moreno Relationship between Plaintiffs and Kremlin/Putin
Michael Movsovich Relevant conduct of Plaintiffs, including business roles,

Myrmidon Group LLC Lobbying on behalf of Plaintiffs and Alfa; Plaintiffs’ relations with
corporate representative the media and US government officials; access to public relations
Corporate representative Public relations and lobbying efforts of Plaintiffs in the US and
of Neue Galerie abroad; Plaintiffs’ investments in the US; Plaintiffs’ interactions
with the media; Plaintiffs’ donations to the Neue Galerie
Corporate representative Receipt and delivery of CIR 112

of the New York Times
Eric Nitcher Relevant conduct of Plaintiffs, including business roles,

Victoria Nuland Relevant conduct of Plaintiffs, Alfa; Government’s receipt,

delivery, and knowledge of CIR 112; Government investigations
into Russian interference in US politics, elections, and policy;
Russian interference in US elections; Russian interference in and/or
influence on US policy; Russian interference in and/or influence on
US politics; communications with Plaintiffs; Plaintiffs’
communications and relationships with US government officials
Representative of the U.S. Relationships, ties, or communications between Plaintiffs and

Office of Foreign Assets Vladimir Putin and/or the Kremlin; relevant conduct of oligarchs
Control (OFAC) and Putin; sanctions on Russian oligarchs and businesses
Richard Palmer Plaintiffs as public figures; Plaintiffs’ notoriety; Plaintiffs’ business

tactics; Plaintiffs’ ties, communications, meetings, and relations
14

acting on their behalf; Alfa’s business tactics; Alfa’s ties,
communications, and relations with the Kremlin, Vladimir Putin,
and those representing them or acting on their behalf; events related
to topics in CIR 112
Javier Perez Dolset Relevant conduct of Plaintiff Mikhail Fridman and Alfa entities;
The Peter G. Peterson Plaintiffs’ donations to charitable organizations and foundations;

Institute for International Plaintiffs’ roles in the business world; Plaintiffs’ notoriety;
Economics corporate Plaintiffs’ communications, positions, and statements concerning
representative U.S. politics; U.S. non-profits and foundations
Stan Polovets Public relations and lobbying efforts of Plaintiffs in the US and
abroad; Plaintiffs’ visits to the White House and contacts with
Adam Posen Plaintiffs’ donations to charitable organizations and foundations;

Plaintiffs’ roles in the business world; Plaintiffs’ notoriety;
U.S. politics, U.S. non-profits and foundations
Bill Priestap Relevant conduct of Plaintiffs, Alfa; FBI’s knowledge of CIR 112;
15
Vladimir Putin Full knowledge of dispute; events described in CIR 112;
Stephen Rademaker Plaintiffs’ lobbying efforts in the U.S. and abroad; Plaintiffs’
Rand Corporation Plaintiffs’ donations to charitable organizations and foundations;

Plaintiffs’ roles in the business world; Plaintiffs’ notoriety;
U.S. politics, US-Russian policy, U.S. non-profits and foundations;
Plaintiffs’ foreign policy experience
Tom Reed Plaintiffs’ roles in the business world; Plaintiffs as public figures;
Plaintiffs’ control of Alfa; Plaintiffs’ business tactics
Alexey Reznikovich Relationship between Plaintiffs and Kremlin/Putin; Plaintiffs’

control of Alfa; Plaintiffs’ corrupt and criminal activity
Ed Rogers Plaintiffs’ lobbying efforts in the U.S. and abroad; Plaintiffs’

Mathew Rojansky Plaintiffs’ interactions with the media; Plaintiffs’ wealth and
notoriety; Plaintiffs’ donations to charitable organizations and
foundations; Plaintiffs’ investments in the United States; Plaintiffs’
roles in the business world; Plaintiffs’ public relations activities in
the United States; Plaintiffs’ lobbying efforts in the United States
and abroad
Jack Rosen Relevant conduct of Fridman; Fridman’s efforts to invest in US real

estate
Laura Rosenberger Plaintiffs’ relationships with the Kremlin/Putin; Plaintiffs’

David M. Rubenstein Plaintiffs’ investments in the United States; Plaintiffs’ wealth and
notoriety
16
Ilia Salita Relevant conduct of Plaintiffs; Plaintiffs’ creation and involvement

Genesis Prize Foundation; Plaintiffs’ public appearances
Peter Salovey Relevant conduct of Petr Aven; Aven’s communications, positions,

and statements concerning U.S. politics, U.S. non-profits and
Aven’s wealth and notoriety; Aven’s donations to charitable
Natan Sharansky Relevant conduct of Plaintiffs; Plaintiffs’ creation and involvement

Plaintiffs’ ties, communications, meetings, and relations with the

Kremlin, Vladimir Putin, and those representing them or acting on
Dimitri Simes their behalf; Plaintiffs’ communications, positions, and statements
concerning U.S. politics; U.S. non-profits and foundations; the
presidential election; the Trump Organization; Government
investigations into Russian interference in U.S. politics, elections,
and policy
Scott V. Simpson Plaintiffs’ corrupt and criminal activity; Plaintiff’s control of Alfa
Ben Smith Relevant conduct of Buzzfeed, recipients of CIR 112; delivery of

CIR 112
Jill W. Smith Relevant conduct of Plaintiffs; Plaintiffs’ creation and involvement

Christopher Steele Experience, work, process, and engagement by Defendants; his

communications with the FBI, Senator John McCain, the U.S.
Department of Justice, and other governmental agencies and
officials; CIR 112, including recipients of CIR 112, research related
17
to matters in CIR 112, events related to topics in CIR 112, and

delivery of CIR 112
Corporate representative Any connections or communications between a server linked to the

of Stroz Freidberg Trump Organization and Alfa server(s)
Bernard Sucher Alfa, including all entities affiliated with Alfa, Alfa’s ties to the
Kremlin and Vladimir Putin, and Alfa’s investments in U.S.
companies; Plaintiffs’ ties, communications, meetings, and
them or acting on their behalf; Plaintiffs’ roles in the business
world
Lawrence Summers Communications with Plaintiffs; relations and communications

between Plaintiffs and US government officials; meetings between
Plaintiffs and US Government Officials; Plaintiffs’ experience with
foreign policy; privatization of Russia
Vladislav Surkov Plaintiffs’ ties, communications, meetings, and relations with the
Kremlin, Vladimir Putin, and those representing them or acting on
their behalf; events related to topics in CIR 112; Russian
interference in and/or influence on U.S. politics, elections, and/or
policy; any connections or communications between a server linked
to the Trump Organization; Alfa’s ties to the Kremlin and Vladimir
Putin, on and Alfa server(s)
Marc Tessier-Lavigne Relevant conduct of Plaintiffs and Alfa; Plaintiffs’ donations to

Representative of Trident Relevant conduct of Plaintiffs and Alfa; Plaintiffs’ ties,

Group, LLC communications, meetings, and relations with the Kremlin,
behalf
Pranav L. Trivedi Relevant conduct of Plaintiffs, including business roles,

Representative of Trump Plaintiffs’ communications, positions, and statements concerning

Organization U.S. politics; U.S. non-profits and foundations; the presidential
election; the Trump Organization; communications with the
Russian government
18
Representative of 2016 Plaintiffs’ communications, positions, and statements concerning

Trump Presidential U.S. politics; U.S. non-profits and foundations; the presidential
Campaign election; the Trump Organization; communications with the
Russian government
Unknown PR Public relations activities of Plaintiffs; Plaintiffs’ prominent roles

representatives of in the business world; Plaintiffs’ interactions with the media
Plaintiffs
Representative of U.S.- Plaintiffs’ ties, communications, meetings, and relations with the
Russia Business Council Kremlin, Vladimir Putin, and those representing them or acting on
their behalf; Plaintiffs’ communications, positions, and statements
concerning U.S. politics; U.S. non-profits and foundations
Anton Vaino Events related to topics in CIR 112; Russian interference in and/or
influence on U.S policy; Plaintiffs’ investments in the United
States; Russian interference in and/or influence on U.S. politics;
Russian interference in U.S. elections; Plaintiffs’ ties,
behalf
Corporate representative Defendants’ research and knowledge of Alfa and Plaintiffs

of the Wall Street Journal
Celeste Wallander Relevant conduct of Plaintiffs, Alfa; Government’s receipt,

delivery, and knowledge of CIR 112; Government investigations
into Russian interference in U.S. politics, elections, and policy;
Russian interference in U.S. elections; Russian interference in
and/or influence on U.S policy; Russian interference in and/or
influence on U.S. politics
Matthias Warnig Relevant conduct of Plaintiffs, including business roles,

events related to topics in CIR 112; Plaintiffs’ relationships with
the Kremlin/Putin
19
Andrew Weissman Relevant conduct of Plaintiffs, including business roles,

Eric J. Wendel Relevant conduct of Plaintiffs, including business roles,

Jonathan Winer Delivery and receipt of CIR 112; privileged publication
Andrej Wolf Relevant conduct of Plaintiffs, including business roles,

Curtis Wolfe Plaintiffs’ investments in the U.S.; Plaintiffs’ roles in the business
Sir Andrew Wood Receipt and delivery of CIR 112
Bob Wood Plaintiffs’ lobbying efforts in the U.S. and abroad; Plaintiffs’
Representative of Yale Relevant conduct of Petr Aven; Aven’s communications, positions,

University’s President’s and statements concerning U.S. politics, U.S. non-profits and
Council on International foundations, the presidential election, the Trump Organization;
Activities Aven’s wealth and notoriety; Aven’s donations to charitable
Rabbi Hirschy Zarchi Plaintiffs contacts with Chabad House; Plaintiffs’ donations to
Ilya Zaslavsky Plaintiffs’ roles in the business world; Plaintiffs’ ties,

behalf; Alfa, including entities affiliated with Alfa; Alfa’s ties to
the Kremlin and Vladimir Putin; Alfa’s investments in U.S.
companies; research related to matters in CIR 112
Mike Zoi Plaintiffs’ investments in the U.S.; Plaintiffs’ roles in the business
20
Debra L. Zumwalt Relevant conduct of Plaintiffs and Alfa; Plaintiffs’ donations to

Alex Van der Zwaan Relevant conduct of German Khan; German Khan’s role in the
business world; German Khan’s relationship with Skadden Arps.
US-Russia Business Plaintiffs’ roles in the business world; Plaintiffs’ notoriety;

Council Plaintiffs’ communications, positions, and statements concerning
U.S. politics; U.S. non-profits and foundations
3. Identify the custodians known to you of any documents concerning the subject
matter of the Action, along with a general description of such documents and, if known, the
documents’ location(s).

broad, and not proportional to the needs of the case, as it seeks information that is not
relevant to any party’s claim or defense in this action. Rule 26(b)(1) limits the scope of
discovery to matters that are “relevant to any party’s claim or defense and proportional to
the needs of the case,” whereas this Interrogatory seeks information “concerning the
subject matter of the Action,” which is broader than the scope permitted by Rule 26(b)(1).
Defendants object to the term “you.” Plaintiffs’ definition of “you” includes “persons or
entities acting . . . in concert with” the Defendants, but information in the possession,
that information.
With respect to that portion of the Interrogatory to which Defendants do not object,
Defendants refer Plaintiffs to Defendants’ Rule 26(a)(1) Initial Disclosures and answer that
the individuals identified therein are likely to have documents concerning the claims and
defenses in this action.
In addition, the following custodians likely have documents concerning the claims and
defenses in this action (where known, Defendants also describe the documents these
custodians likely have): U.S. Department of Justice, including all of the agencies and
bureaus that report thereto, e.g., the Federal Bureau of Investigation (FBI); the Office of
the Director of National Intelligence (ODNI) and all of the members of the U.S.
Intelligence Community that report thereto, e.g., Central Intelligence Agency (CIA) and
National Security Agency (NSA); U.S. Senate Select Committee on Intelligence, U.S.
Senate Judiciary Committee, U.S. House Permanent Select Committee on Intelligence, and
U.S. House Judiciary Committee, all of which likely have documents related to their
respective investigations into Russian interference in the 2016 U.S. presidential election,
including testimony and documents from witnesses; U.S. Department of Treasury
(documents related to Mikhail Fridman’s and Petr Aven’s meeting with Secretary Paulson,
21
for instance); U.S. Federal Reserve (documents concerning Alfa’s efforts to obtain U.S.
banking licenses); U.S. Department of Commerce; U.S. Department of Energy; U.S.
Department of State; the Committee on Foreign Investment in the United States
(documents about national security concerns involving Plaintiffs); Center for Public
Integrity (documents received in the course of litigation with Mikhail Fridman, Petr Aven,
and OAO Alfa Bank); David Corn; Florida Office of Financial Regulation (documents
concerning attempts by Plaintiffs to engage in banking activities); Norex Petroleum Ltd.
(corrupt activities involving plaintiffs in Russia and elsewhere); Marks & Sokolov (corrupt
activities involving Plaintiffs in Russia and elsewhere); Telenor (corrupt activities
involving plaintiffs in Russia and elsewhere), United Nations (corrupt activities in Iraq),
Hogan Lovells (IPOC and other matters involving Plaintiffs’ involvement in Russian
politics); Government of the Netherlands (Plaintiffs’ involvement in corruption); Jeff
Sessions; Vitaly Pruss and TriGlobal Strategic Ventures; Peter S. Watson and Armitage
Associates, LC; Hoover Institution: Inventory of the David E. Hoffman papers; UK
Financial Conduct Authority.
Defendants do not know the location of these documents.
4. Identify all sources consulted by Steele and individuals who contributed to, or
assisted Steele, in connection with investigating and compiling the information in CIR 112
and the Dossier, including any employees or contractors of Orbis, intermediaries, third party
sources, or government contacts or officials.
ANSWER: Objection. Defendants object to this Interrogatory to the extent it asks them to
identify information concerning “the Dossier” because that calls for information that is not
relevant to any party’s claim or defense. Specifically, because Plaintiffs claim they were
defamed by statements in CIR 112, not by “the Dossier,” information concerning the
sources “who contributed to, or assisted Steele” with regard to CIR reports other than CIR
112 is not relevant to any party’s claims or defense.
With respect to the non-objectionable portion of the Interrogatory, Defendants answer that
they do not know the identity of Steele’s sources for CIR 112.
5. Identify and describe the steps that you took, methods you employed,
procedures undertaken, and/or sources you consulted (and dates thereof) to verify or
research the truth or falsity of the information contained in CIR 112 and the Dossier prior
to January 10, 2017.
ANSWER: Objection. Defendants object to this Interrogatory on the grounds that it calls
for information that is protected by the attorney-client and attorney work product
privileges. Defendants object to this Interrogatory to the extent it asks them to identify
steps taken to verify or research the information contained in “the Dossier” because that
calls for information that is not relevant to any party’s claim or defense. Specifically,
because Plaintiffs claim they were defamed by statements in CIR 112, not by “the Dossier,”
methods used to verify statements in reports other than CIR 112 are not relevant.
Defendants object to the term “you,” because Plaintiffs define “you” to include “persons
or entities acting . . . in concert with” the Defendants, but information in the possession,
22
that information.
Regarding the non-objectionable portion of the Interrogatory, Defendants answer:
Defendant Glenn Simpson and the principals of Defendant Bean LLC are former
journalists and/or editors, and they applied journalistic methods and procedures to
verifying and researching the information in CIR 112. Those methods consist primarily of
the acquisition and review of public information, such as books and news articles,
government records, and court filings.
Defendants obtained CIR 112 from a trusted, experienced, and well-respected source:
Christopher Steele, who for more than 20 years had worked in Britain’s Secret Intelligence
Service, MI6, focusing on Russia. In the later part of his career, Mr. Steele ran the Russia
desk at MI6 headquarters. Mr. Steele had worked with the FBI and U.S. intelligence
services on other high profile, international investigations. In and around the time they
received CIR 112, Defendants had conversations with Mr. Steele that covered topics such
as the content of CIR 112, the quality of the sourcing, the competence of Mr. Steele’s team,
the potential for misinformation, and efforts to verify the information in CIR 112.
Defendants obtained and evaluated CIR 112 in the context of events that corresponded with
information in CIR 112. These events occurred prior to and after Defendants’ receipt of
CIR 112, such as news reports that were published before and after Defendants obtained
CIR 112 and other public records, corroborating information in CIR 112 and furthering
Defendants’ belief that the information contained in CIR 112 was credible and accurate.
For example, Defendants had seen reporting of a server registered to the Trump
Organization that might have been communicating almost exclusively with a server owned
by Alfa, which Plaintiffs own and control.
For years, Defendants had conducted extensive research on Alfa, Plaintiffs, Russian
organized crime, Russian oligarchs, corruption in Russia, US government concerns and
warnings about the increasing involvement of Russian oligarchs in the American economy
and political system, foreign interference in American elections, and other related topics,
which helped corroborate information in CIR 112. Cross-checking the information in CIR
112 against publicly available records, Defendants found material that supported CIR 112
and found nothing to contradict it.
Defendants, and in particular Defendant Glenn Simpson, have extensive knowledge and
expertise on Alfa, Russia, the Kremlin, foreign interference in US elections, Russian
organized crime, Russian lobbying and public relations activities in the United States, and
transnational crimes. They concluded that the information in CIR 112 corresponded with
their research and understanding of these areas. For instance, while a journalist, Defendant
Simpson for many years investigated the Alfa-IPOC dispute, during which he discovered
that the Plaintiffs were politically and legally “protected” within Russia and that Putin and
the Kremlin would give Plaintiffs a free hand to engage in Russian-style corporate raiding
(“reiderstvo”) and use aggressive and legally questionable methods to pursue their business
23
and political objectives without fear of restraint or reprisals such as imposed by the Kremlin
on other oligarchs.
6. Identify your standard policies or methodologies, if any, relating to verifying

or researching information obtained from investigative firms prior to publishing or
disseminating the information to third parties, including clients or the media, and whether
any such policies are in writing.
ANSWER: Objection. Defendants object to the phrase “standard policies or

methodologies” because it is vague and it is unclear what is meant by this, specifically the
term “standard.” Defendants further object that the Interrogatory calls for a legal
conclusion insomuch as it requests identification of policies for verifying information prior
to “publishing” the information, as publication is a legal term of art. Defendants object to
the term “your,” because Plaintiffs define “your” to include “persons or entities acting . . .
in concert with” the Defendants, but information in the possession, custody, or control of
persons or entities acting “in concert with” the Defendants is not in Defendants’ possession,
custody, or control and the Defendants therefore cannot provide that information. To the
extent Plaintiffs are asking for a recitation of a written document describing Defendants’
methods for “verifying or researching information obtained from investigative firms,”
Defendants answer that no such document exists.
With respect to the non-objectionable portion of the Interrogatory, Defendants answer that
they rely on their extensive experience as investigative journalists and/or editors and the
journalistic skills they have honed over their careers to research, evaluate, and verify the
accuracy, credibility and reliability of information they obtain through their work. When it
comes to human intelligence, as was involved in CIR 112, Defendants employ various
methods to evaluate the credibility of the information. For instance, similar to the interview
process in journalism, Defendants research the names, places, and people in the
information they receive to see if it matches information from other sources, such as
scholarly work on the subject or public records. In other words, they examine whether the
details check out and whether they make sense. Defendants also look into whether
information from other sources supports or contradicts information from the human
intelligence source. Defendants evaluate whether the information provided corresponds
with their own knowledge of the topic. Defendants also evaluate the credibility and
reliability of their sources, including the source’s methods, the source’s experience, the
source’s professional background, the source’s access to information, and whether the
source has provided reliable information in the past. Defendants engage in these sorts of
checks and processes to evaluate whether the human intelligence information they receive
is credible.
7. Identify and describe your receipt of the CIRs constituting the Dossier,
including CIR 112, that were “delivered to [you] over the course of several months in 2016,”
as alleged in Paragraph 3 of the Answer, including the date(s), the sender, the recipient, and
the delivery format.
ANSWER: Objection. Defendants object to this Interrogatory because it is overly broad

and calls for information that is not relevant to any party’s claim or defense, as it asks for
24
information about the receipt of CIRs other than CIR 112, but Plaintiffs claim only that
they were harmed by the alleged publication of statements in CIR 112. Accordingly,
information about the receipt of other CIRs is not relevant. Defendants object to the terms
“you” and “your,” because Plaintiffs define them to include “persons or entities acting . . .
in concert with” the Defendants, but information in the possession, custody, or control of
persons or entities acting “in concert with” the Defendants is not in Defendants’ possession,
custody, or control and the Defendants therefore cannot provide that information.
To the extent the Interrogatory is limited to CIR 112, Defendants answer that they do not
recall the exact date of the transmission of CIR 112. Laura Seago at Defendant Bean LLC
received CIR 112 via a PGP link on or just after the date of CIR 112, September 14, 2016.
Sam Stainer, at Orbis, transmitted CIR 112 to Ms. Seago.
8. Identify all persons, including representatives of Orbis, Perkins Coie, McCain,

Kramer, BuzzFeed, members of the media, the FBI, government employees or officials, and
members of Congress, with whom you communicated regarding Plaintiffs, CIR 112, the
Dossier, or publication of the Dossier.
ANSWER: Objection. Defendants object to this Interrogatory because it is overly broad,

vague, and requests information that is not relevant to any party’s claims or defenses in
this action, and is not proportional to the needs of this case, because the Interrogatory does
not limit the request to a specified time period and because it seeks communications with
“all persons,” without any limitation. Defendants also object that in seeking
communications with “all persons” without limitation in time, the Interrogatory seeks
information that has no bearing on the alleged defamatory statements in CIR 112 and
therefore will not help resolve the issues before the court. Moreover, the Interrogatory asks
for information that is not relevant because it asks for communications concerning “the
Dossier, or publication of the Dossier,” but Plaintiffs’ claims in this action are limited to
statements in CIR 112. Defendants further object that the Interrogatory calls for a legal
conclusion insomuch as it requests information concerning “publication” of the Dossier.
Defendants also object to the term “you,” because Plaintiffs define “you” to include
“persons or entities acting . . . in concert with” the Defendants, but information in the
possession, custody, or control of persons or entities acting “in concert with” the
Defendants is not in Defendants’ possession, custody, or control and the Defendants
therefore cannot provide that information.
The term “communicated” is likewise vague. Inasmuch as Defendants communicated with

anyone at Perkins Coie LLP, those communications are protected by the attorney-client
privilege and the attorney work product doctrine, and Defendants are not authorized to
waive those privileges.
Supplemental Answer: Defendants agreed, through the meet and confer process, to
supplement this answer to identify the people with whom Defendants discussed CIR 112
or Plaintiffs prior to January 10, 2017.
Defendants recall discussing CIR 112 with: Christopher Steele; Marc Elias; Michael
Sussman.
25
Defendants recall communicating about Plaintiffs with: Christopher Steele; Marc Elias;
Michael Sussman; Franklin Foer; Newt Royce; Peter Eisner; Charles Lewis; Catherine
Belton; Connie Bruck; Mark Hosenball; Eric Lichtblau; Michael Isikoff.
9. Identify and describe each transmission, delivery, oral or written

communication, or publication by you, Steele, or Orbis of the Dossier or any of the CIRs (or
information contained in such CIRs), including CIR 112, to any third persons, including
Perkins Coie, McCain, Kramer, Winer, BuzzFeed, members of the media, government
employees or officials, and members of Congress, as set forth in Paragraphs 1 through 3 of
the Affirmative Defenses in the Answer. Include the date(s), the sender, the recipient, and
the delivery format.
ANSWER: Objection. Defendants object to this Interrogatory in part because it seeks

discovery that is not relevant to any party’s claim or defense as it seeks information
concerning each transmission, delivery, etc. of “any of the CIRs.” Plaintiffs’ claims of
defamation relate only to the alleged publication of CIR 112. Accordingly, information
about the transmission of other CIRs is not relevant to any party’s claim or defense.
Defendants also object to this Interrogatory on the grounds that it calls for information that
is protected by the attorney-client and attorney work product privileges, because it asks for
information about communications between Defendants and Perkins Coie, and Defendants
are not authorized to waive such privileges. Defendants further object that the Interrogatory
calls for a legal conclusion insomuch as it requests a description of each “publication,” a
legal term of art. Defendants also object to this Interrogatory as overly broad, vague, and
not proportional to the needs of this case, because it does not specify a time period for the
information requested. Defendants also object to the term “you,” because Plaintiffs define
“you” to include “persons or entities acting . . . in concert with” the Defendants, but
information in the possession, custody, or control of persons or entities acting “in concert
with” the Defendants is not in Defendants’ possession, custody, or control and the
Defendants therefore cannot provide that information.
With respect to the non-objectionable parts of the Interrogatory, and to the extent the time
period for the request is limited to prior to January 10, 2017, and the request is limited to
information concerning CIR 112 only, Defendants answer as follows.
Defendant Glenn Simpson provided an electronic copy of CIR 112 to Bruce Ohr, U.S.
Department of Justice employee, at some point after Thanksgiving of 2016.
Defendants provided David Kramer with a copy of CIR 112 at some point in late November
or December 2016.
Defendants provided a hard copy of CIR 112 to the New York Times, at some point in
November or December of 2016.
Defendants provided a copy of CIR 112 to David Corn of Mother Jones in November 2016.
Defendants showed a hard copy of CIR 112 to Jonathan Winer on or around September 23,
2016.
26
SUPPLEMENTAL ANSWER: Defendants agreed, as part of the meet and confer

process, to supplement their answer to this interrogatory to identify the names of the New
York Times reporters with whom they shared CIR 112 or the Dossier, to the extent
Defendants recall the names.
Defendants recall sharing CIR 112 or the Dossier with the following New York Times
reporters: Mark Mazzetti; Steven Lee Myers; Eric Lichtblau; Scott Shane; Matt Apuzzo.
10. Identify any code names or other names you used for matters relating to CIR
112 or the Dossier.
ANSWER: Objection. Defendants object to this Interrogatory as seeking information that

is not relevant to any party’s claim or defense because it asks for code names “used for
matters relating to … the Dossier.” Plaintiffs’ claims of defamation relate only to the
alleged publication of CIR 112. Accordingly, information about the Dossier is not relevant
to any party’s claim or defense. Defendants object to the term “you,” because Plaintiffs
define “you” to include “persons or entities acting . . . in concert with” the Defendants, but
As to the remaining portion of the Interrogatory to which Defendants do not object,

Defendants answer that the name that Defendant Bean LLC used for its project
investigating Trump’s activities and dealings in Russia was “Bangor.”
11. Identify and describe the circumstances of your engagement by the

Washington Free Beacon in 2015 and by Perkins Coie (or the Democratic National
Committee, the campaign of Hillary Clinton, or HFACC, Inc.), as referenced in Paragraph
15 of the Answer, including the scope of the engagement, the persons with whom you
communicated, documents memorializing the engagement, and the amounts paid to you in
connection with such engagements.
ANSWER: Objection. Defendants object to this Interrogatory because it calls for

information that is not relevant to any party’s claims or defenses, because Defendants did
not engage with Orbis or receive CIR 112 as part of Defendants’ engagement with the
Washington Free Beacon. Defendants also object to this Interrogatory on the grounds that
it calls for information that is protected by the attorney-client and attorney work product
privileges, because it asks for information about communications between Defendants and
Perkins Coie, and Defendants are not authorized to waive such privileges. Defendants
object to the terms “you” and “your,” because Plaintiffs define “you” to include “persons
or entities acting . . . in concert with” the Defendants, but information in the possession,
that information.
With respect to the non-objectionable portion of this Interrogatory, Defendants answer that
with respect to Perkins Coie, their engagement began approximately April 1, 2016, and
27
ended on or about the end of October 2016/early November 2016. Perkins Coie engaged
Defendants to provide consulting services in support of Perkins Coie’s rendering of legal
advice to its clients, including with respect to actual and potential litigation. Defendants’
consulting services in support of Perkins Coie’s provision of legal advice to its clients
included research, such as requesting, pulling, and analyzing publicly available records,
and compiling information gathered by its subcontractors. Defendants communicated
primarily with Marc Elias at Perkins Coie. Perkins Coie paid Defendants $50,000 per
month pursuant to the terms of the engagement, and a total of approximately $1,024,000.
Defendants refer Plaintiffs to the non-privileged, responsive, relevant documents regarding
the engagement and payment.
12. Identify and describe the circumstances of your engagement of Orbis and/or
Steele, as referenced in Paragraph 3 of the Answer, including the scope of the engagement,
the persons with whom you communicated, documents memorializing the engagement, and
amounts paid to Orbis and/or Steele in connection with such engagements.
ANSWER: Defendants object to the terms “you” and “your,” because Plaintiffs define
Defendants’ initial engagement of Orbis was for 20 or 30 days, and Defendants paid Orbis
a set amount of money to look into then-candidate Trump’s activities in Russia, in support
of Defendants’ ongoing research activities, without further specifying any goal or result.
The total amount ultimately paid to Orbis was approximately $162,000. At Orbis,
Defendants mainly communicated with Sam Stainer, Tatiana Duran, Christopher Steele,
and Christopher Burrows. Defendants had an engagement letter with Orbis at one point,
but they no longer have it. Defendants refer Plaintiffs to documents that have been
produced concerning Orbis’s engagement.
13. Identify what you knew on or before January 10, 2017 about whether CIR 112
was the subject of any judicial proceeding, legislative proceeding, or other official
proceeding, and identify the basis for any such knowledge and all documents in support
thereof.
ANSWER: Objection. This Interrogatory calls for information that is based on privileged
information, because it implicates information that is protected by the attorney-client
privilege and the attorney work product doctrine. Defendants object to the term “you,”
because Plaintiffs define “you” to include “persons or entities acting . . . in concert with”
the Defendants, but information in the possession, custody, or control of persons or entities
acting “in concert with” the Defendants is not in Defendants’ possession, custody, or
control and the Defendants therefore cannot provide that information.
Defendants can provide the following information without implicating privileged

communications:
28
• In or around September 2016, the FBI, through FBI special agent and assistant
legal attaché in Rome Michael Gaeta, asked Christopher Steele for copies of the
intelligence reports Mr. Steele had compiled in what is now referred to as the
Dossier, including CIR 112. Mr. Steele told Defendants about this request from
the FBI and his compliance with it. As Simpson testified to the Senate Judiciary
Committee, Steele informed Simpson in September 2016 with words to this
effect: “I heard back from the FBI and they want me to come talk to them and
they said they want everything I have.” The urgency was such that the FBI
requested that Mr. Steele fly to Rome. Afterwards, he informed Simpson, “I
gave them a full briefing.”
• In November or December 2016, Senator John McCain asked Christopher

Steele for copies of the intelligence reports Mr. Steele had compiled in what is
now referred to as the Dossier, including CIR 112. Mr. Steele, through Glenn
Simpson and David Kramer, had these reports delivered to Senator McCain.
Defendants knew that Senator McCain had asked for and received CIR 112
because Mr. Steele told them.
• In or around November 2016, Bruce Ohr of the U.S. Department of Justice,

asked Mr. Steele for copies of the intelligence reports Mr. Steele had compiled
in what is now referred to as the Dossier, including CIR 112.
• On or around September 23, 2016, Jonathan Winer of the U.S. Department of

State asked to review copies of the intelligence reports Mr. Steele had compiled
in what is now referred to as the Dossier, including CIR 112.
14. Identify and describe the steps that you took, methods you employed,
procedures undertaken, and/or sources you consulted (and the dates thereof) to ascertain
whether CIR 112 was the subject of any judicial proceeding, legislative proceeding, or other
official proceeding, including any official government proceeding or action, briefings of
President Obama and/or President-elect Trump, and any investigation or other inquiry by
the Federal Bureau of Investigations.
ANSWER: Objection. Defendants object to the term “you,” because Plaintiffs define
Defendants refer Plaintiffs to their answer to Interrogatory No. 13.
15. Identify each of the Briefings, the persons who attended the Briefings, and
your involvement in any of the Briefings, including whether you attended the Briefings and
with whom you communicated regarding the Briefings prior to them taking place, as
Simpson testified about on August 22, 2017 before the Senate Judiciary Committee (Tr. at
205-09).
29

information that is not relevant to any party’s claims or defenses, because Defendants have
no recollection of any discussion of the contents of CIR 112 at these Briefings and do not
believe any such discussion occurred owing to the introductory and general nature of these
discussions. Defendants also object to the terms “you” and “your,” because Plaintiffs
define “you” to include “persons or entities acting . . . in concert with” the Defendants, but
SUPPLEMENTAL ANSWER: Defendants do not waive any of their objections and

continue to maintain that they do not recall discussing CIR 112 or Plaintiffs at the
Briefings. Defendants agreed to supplement their answer to disclose the names of the
people with whom they recall meeting at the Briefings:
Michael Isikoff, Jane Mayer, David Sanger, Eric Lichtblau, Matthew Mosk, Tom
Hamburger, Dana Priest
16. Identify any and all litigation, court proceedings, governmental proceedings,
or government agency requests in which you produced documents or provided information
(or in which you received documents or information) concerning the Dossier, CIR 112,
Plaintiffs, or subject matter of this Action.

broad, and seeks information that is not proportional to the needs of the case because it
asks for information that is not relevant to any party’s claims or defenses in this action.
Rule 26(b)(1) limits the scope of discovery to matters that are “relevant to any party’s claim
or defense and proportional to the needs of the case,” whereas this Interrogatory seeks
information “concerning … the subject matter of this Action,” which is broader than the
scope permitted by Rule 26. Defendants also object because it is unclear what is meant by
“provided information.” Defendants object to the term “you,” because Plaintiffs define
Defendants answer this request as it applies to CIR 112, interpret “provided information”
to mean testimony or affidavits, and exclude the definition of “you” objected to herein.
Defendants answer that they produced documents or provided information in the following
proceedings:
• U.S. Senate, Senate Judiciary Committee
• U.S. Senate, Senate Select Committee on Intelligence
• U.S. House of Representatives, Permanent Select Committee on Intelligence,

Investigation into Russian Active Measures
30
• Bean LLC v. John Doe Bank, 17-cv-2187 (D.D.C.)
• Gubarev v. Buzzfeed, Inc., Case No. 0:17-cv-60426-UU (S.D. Fla.)
17. Identify the occurrence, dates, and context for any testimony or interviews,
including but not limited to deposition testimony, that you have given or taken in any
litigation or court or government proceeding (including Congressional activity) concerning
the Dossier, CIR 112, or the subject matter of this Action.

broad, and seeks information that is not proportional to the needs of the case because it
asks for information that is not relevant to any party’s claim or defense in this action. Rule
26(b)(1) limits the scope of discovery to matters that are “relevant to any party’s claim or
defense and proportional to the needs of the case,” whereas this Interrogatory seeks
information “concerning … the subject matter of this Action,” which is broader than the
scope permitted by Rule 26. Defendants object to the term “you,” because Plaintiffs define
In addition, Defendants object because this Interrogatory calls for information that is
required to be kept highly confidential pursuant to a protective order. Accordingly,
Defendants answer this Interrogatory excluding the definition of “you” objected to herein,
and only as to CIR 112, and do not answer as to information subject to a protective order.
• U.S. Senate, Senate Judiciary Committee, Committee to Investigate Russia, August 22,
2017, voluntary interview of Glenn Simpson at the Committee’s request
• U.S. Senate, Senate Select Committee on Intelligence, Nov. 15, 2017, voluntary
interview of Glenn Simpson at the Committee’s request
• U.S. House of Representatives, Permanent Select Committee on Intelligence,

Investigation into Russian Active Measures, November 14, 2017, Interview of Glenn
Simpson; November 8, 2017, voluntary interview of Glenn Simpson at the
Committee’s request
• Gubarev v. Buzzfeed, Inc., Case No. 0:17-cv-60426-UU (S.D. Fla.), August 30, 2018,
Deposition of Peter Fritsch, pursuant to subpoena
• Bean LLC v. John Doe Bank, 17-cv-2187 (D.D.C.), Declaration of Peter Fritsch in
Support of Fusion’s Unopposed Motion for Temporary Restraining Order and
Preliminary Injunction (Oct. 19, 2017); Second Declaration of Peter Fritsch in Support
of Fusion GPS’s Motion for a Temporary Restraining Order and Preliminary Injunction
(October 23, 2017).
31
18. Identify any documents or evidence reflecting or demonstrating any

“questionable, unethical and illegal conduct” by Plaintiffs concerning “the entanglement of
Russian oligarchs’ political and business interests and those of the Russian state and/or
President Putin,” as referenced in Paragraph 13.a. of the Affirmative Defenses in the
Answer.
ANSWER: Defendants refer Plaintiffs to the news articles, publications, and judicial
decisions cited in their Memorandum of Points and Authorities in Support of Defendants’
Motion to Dismiss the Amended Complaint for Failure to State a Claim, Dkt. No. 20-1, in
this Action; the documents Defendants will be producing; as well as additional examples
of such information, including:
• Background Investigation and Assessment of Tyumen Oil Company, Confidential

BP Memo, 9 September 1999
• Fusion GPS, Alfa Access Memo, Feb. 7, 2012
• Fusion GPS, Ames Report, Feb 15, 2012
• Fusion GPS, Ames Update, Sept. 5, 2012
• Fusion GPS, DT Russia, Draft Open Source Report, 4 March 2016
• Edward Baumgartner, Report re: ALFA Dossier Open Source
• Fusion GPS, Conflict With IPOC, date unknown
• The Alfa Playbook, due diligence report, source unknown
• Letter from Alex Rotzang, CEO, Norex to Redacted Personnel in Washington

DC, Aug. 30, 2004. Evidence of US Citizens and Corporations Involvement In
Iraq Oil Deals; Crown/TNK/Alfa-Eco/Bayoil Iraq Oil Price and Oil Transactions
Manipulations
• Information about the materials regarding Mr. Fridman M.M., Mr. Kuzmichev
A.V., Mr. Khan G.B., Mr. Blavatnik L., Mr. Vekselberg V.F., (Export-Import
Bank files), a due diligence report, source unknown
• Undated Due Diligence report on Alfa Bank, Peter Bond, Valmet, Menatep
(source unknown)
• Letters to Export-Import Bank regarding TNK, from US Congress, House of

Representatives, November and December 1999, filed as exhibits to the
Declaration of Philip Murray in Norex Petroleum Ltd. v Access Industries, Inc.,
Case No. 02-cv-1499 (S.D.N.Y., complaint filed Feb. 26, 2002).
32
• Translation of August 9, 2001 Letter to Vladimir Remizyuk, Investigator, Russian

Ministry of Internal Affairs from A.V. Kuzmitchev re: Alfa-Eco’s legal problems
• Donor List, New Economic School, 2016 -

https://web.archive.org/web/20160916074601/http://www.nes.ru/ru/school/manag
ement/
• Correspondence from V.V. Putin to P.O. Aven on Purchasing Food from Abroad,
http://miamioh.edu/cas/_files/documents/havighurst/salye/From%20VV%20Putin
%20to%20PO%20Aven%20on%20Purchasing%20Food%20From%20Abroad.pd
f
• Correspondence Between AP Pakhonov and PO Aven on NorthWest Region and

Committee on Foreign Economic Relations of St. Petersburg,
http://miamioh.edu/cas/_files/documents/havighurst/salye/Correspondence%20Be
tween%20AP%20Pakhonov%20and%20PO%20Aven%20on%20NorthWest%20
Region%20and%20Committee%20on%20Foreign%20Economic%20Relations%
20of%20St%20Petersburg.pdf
• “RUSSIA – Russian tandem power shifts analyzed in wake of Medvedev’s

reshuffle,” https://wikileaks.org/gifiles/docs/13/131883_russia-russian-tandem-
power-shifts-analyzed-in-wake-of.html
• Alfa Group: Our Businesses, http://www.alfagroup.org/business/investment/a1/

(last visited Oct. 28, 2019)
• Official Photo of Aven Meeting Putin in 2010,

http://archive.premier.gov.ru/eng/events/news/11335/
• Exhibits filed in Norex Petroleum Ltd. v Access Industries, Inc., Case No. 02-cv-
1499 (S.D.N.Y., complaint filed Feb. 26, 2002)
• Exhibits filed in Norex Petroleum Ltd. v. Blavatnik, Case. No. 650591-2011 (N.Y.
Sup. Ct., complaint filed March 7, 2011)
• Exhibits A & C to Affidavit of Barry Ostrager (filed Oct. 26, 2011), Norex
Petroleum Ltd. v. Blavatnik, 0650691-2011 (N.Y. Sup. Ct)
• Information (Dkt. No. 2), United States v. Vimpelcom Ltd., Case No. 1:16-cr-
00137-ER (filed Feb. 18, 2016).
• RSM Production Corp. v. Fridman, Case No. 1:06-cv-11512-EJW (S.D.N.Y.,

filed Nov. 1, 2006) (complaint and exhibits filed therein)
• Fourth Affidavit of Jeffrey Galmond and exhibits, Aug 6, 2004, IPOC

International Growth Fund Limited v. LV Finance Group Ltd., Eastern Caribbean
Supreme Court (BVI)
33
• Transcript of Conversation between James Hatt and Jeff Galmond (Sept. 6, 2004),
Exhibit 4, Second Affidavit of Christopher George Hardman, IPOC International
Growth Fund Limited v. LV Finance Group Ltd., Eastern Caribbean Supreme
Court (BVI)
• Investigation Report to Fiscalía Especial Contra Corrupción y Crimen Organizado

(Special Prosecutor for Corruption and Organized Crime), May 10, 2017,
https://tbcarchives.org/wp-content/uploads/HANTA.-Fridman.pdf
• Complaint, Special Prosecutor for Corruption and Organized Crime,

https://criminalarchive.com/wp-content/uploads/Fridman-Engibaryan-Dolcet-
Spain.pdf
• Landeskriminalamt Baden-Württemberg (Office of Criminal Investigation),

https://tbcarchives.org/wp-content/uploads/Ismailovskaja-Vernehmung-LG-
Stuttgart-1.pdf
• The Russian Presidential Elections, Hearing Before the Subcomm. on European

Affairs, U.S. Senate, Committee on Foreign Relations, Sen. Arg. 106-702 (April
12, 2000), https://www.gpo.gov/fdsys/pkg/CHRG-106shrg67222/html/CHRG-
106shrg67222.htm
• Russian Government and the Politics-Business Nexus: 1998-2003, Hearing

Before the Senate Permanent Subcommittee on Investigations, May 17, 2005
(Testimony by Peter Reddaway),
https://www.hsgac.senate.gov/imo/media/doc/STMTReddaway.pdf
• Andrew Jack, Inside Putin’s Russia 203 (2004)
• Peter Baker & Susan Glasser, Kremlin Rising: Vladimir Putin’s Russia and the
End of Revolution 286 (2005)
• Anna Politkovskaya, A Russian Diary: A Journalist’s Final Account of Life,

Corruption, and Death in Putin’s Russia 260 (2007)
• Lilia Shevtsova, Putin’s Russia 87 (2010)
• David E. Hoffman, The Oligarchs: Wealth and Power in the New Russia (2011)
• Yuri Felshtinsky & Vladimir Pribylovsky, The Putin Corporation: The Story of
Russia’s Secret Takeover 72 (2012)
• Fiona Hill & Clifford G. Gaddy, Mr. Putin: Operative in the Kremlin 174, 227
(2013)
• Petr Aven & Alfred Kokh, Gaidar’s Revolution (2015)
34
• Karen Dawisha, Putin’s Kleptocracy: Who Owns Russia 196 (2015)
• Mikhail Zygar, All the Kremlin’s Men: Inside the Court of Vladimir Putin (2016)
• Reporting on Russia By GR Simpson, reporting archive, created 2009
• “Alleged violations in the Chernogorneft Bankruptcy Process,” CIA Letter, June

3, 2003, https://www.cia.gov/library/readingroom/docs/DOC_0001341232.pdf
• “The ‘Evolving Oligarch’,” Institutional Investor, Sept. 1, 2003,

https://www.institutionalinvestor.com/article/b15135r36rgw6y/the-evolving-
oligarch
• Paul Volcker et al., “Manipulation of the Oil-For-Food Programme by the Iraqi

Regime,” United Nations Oil for Food Report, (Oct. 27, 2005)
https://www.foxnews.com/projects/pdf/final_off_report.pdf
• “Kremlin Unhappiness Causes Moscow’s ‘Domashniy’ Channel to Pull Talk

Show,” Wikileaks Cable, Sept. 21, 2006,
https://wikileaks.org/plusd/cables/06MOSCOW10605_a.html
• Stratfor, “Mikhail Fridman: Profile and Perception,” Jan. 29, 2007,

https://wikileaks.org/gifiles/attach/175/175793_Mikhail%20Fridman%20-
%20Profile%20and%20Perception.pdf
• Stratfor, “Mikhail Fridman: Background Investigation,” Aug. 3, 2007,

https://wikileaks.org/gifiles/attach/175/175991_Mikhail%20Fridman%20-
%20Background%20Investigation.pdf
• “What’s Behind the Raids on TNK-BP and BP,” Wikileaks Cable, Mar. 28, 2008,
https://wikileaks.org/plusd/cables/08MOSCOW864_a.html
• “TNK-BP Update: Court Bars Dudley From Post for Sham Labor Violations,”
Passed to the Telegraph by Wikileaks, Jan. 31, 2011 (cable dated Aug. 18, 2008),
https://www.telegraph.co.uk/news/wikileaks-files/bp-wikileaks/8294146/TNK-
BP-UPDATE-COURT-BARS-DUDLEY-FROM-POST-FOR-SHAM-LABOR-
VIOLATIONS.html
• Thomas Firestone, “Criminal Corporate Raiding in Russia,” 42 Int’l L. 1207

(2008)
• Luke Harding, “Oil: ‘Harassed’ Head of BP Venture Exits Moscow,” The

Guardian, July 25, 2008,
https://www.theguardian.com/business/2008/jul/25/bp.oil
• Anastasia Kirilenko, “Why Marina Salie Was Silent About Putin for 10 years?”
Radio Liberty, March 2, 2010, https://www.svoboda.org/a/1972366.html
35
• Vladimir Ivanidze, “Saving Lieutenant Colonel Putin: The Second Attempt,”

Radio Liberty, March 16, 2010, https://www.svoboda.org/a/1983851.html
• Mikhail Fridman, “How I Became an Oligarch,” (Lecture, Lviv, Ukraine, Nov.

14, 2010), https://www.opendemocracy.net/od-russia/mikhail-fridman/fridman-
how-i-became-oligarch
• Gregory L. White, “TNK-BP Russian Partner Relishes Conflict,” Wall St. J., Nov.
14, 2011,
https://www.wsj.com/articles/SB100014240529702035032045770360008547678
04
• Bill Alpert, “How a Putin Aide Gained $119 Million,” Barron’s, Dec. 3, 2011,
https://www.barrons.com/articles/SB500014240527487038278045770561918741
19450
• Vladimir Soldatkin & Andrew Callus, “Rosneft Pays Out in Historic TNK-BP
Deal Completion,” Reuters, March 21, 2013, https://www.reuters.com/article/us-
rosneft-tnkbp-deal/rosneft-pays-out-in-historic-tnk-bp-deal-completion-
idUSBRE92K0IZ20130321
• Memorandum from Mikhail Fridman to Anton Kudryashov, May 29, 2013 (Zed
Plus) - https://www.elconfidencial.com/empresas/2017-01-23/los-informes-de-
pricewaterhouse-sobre-los-sobornos-de-zed-en-rusia_1319784/
• Connie Bruck, “The Billionaire’s Playlist,” The New Yorker, Jan. 12, 2014,
https://www.newyorker.com/magazine/2014/01/20/the-billionaires-playlist
• Philip Hanson, “Reiderstvo: Asset-Grabbing in Russia,” Chatham House, March

1, 2014, https://www.chathamhouse.org/publications/papers/view/198133
• Michael Weiss, “The Kremlin’s $220 Million Man,” Foreign Policy, Oct. 29, 2014,
http://foreignpolicy.com/2014/10/29/the-kremlins-220-million-man/
• Nathan Vardi, “The Four Horsemen of Russia’s Economic Apocalypse,” Forbes,

Jan. 21, 2015, https://www.forbes.com/sites/nathanvardi/2015/01/21/the-four-
horsemen-of-russias-economic-apocalypse/#666f90001542
• RWE Utility Closes $5.7 Billion Deal,” Oil & Gas 360, March 2, 2015,
https://www.oilandgas360.com/rwe-utility-closes-5-7-billion-deal/
• “Putin Advises Russian Businessmen To Wait To Sell Their Assets In Ukraine,”

UAWire, March 25, 2016, http://uawire.org/news/putin-advises-russian-
businessmen-to-wait-to-sell-their-assets-in-ukraine#
• “Putin Awarded Five Russian Billionaires,” Gazeta, May 29, 2015,

https://www.gazeta.ru/business/news/2015/05/29/n_7241257.shtml
36
• “Armenia: The Vanishing Profits,” Internet Ownership Project, Sept. 28, 2015,
https://www.reportingproject.net/internetownership/?p=111
• Stephen Grey & Elizabeth Piper, “Putin’s Older Daughter: A Specialist In

Biomedical Science,” Reuters, Nov. 10, 2015, https://www.reuters.com/article/us-
russia-capitalism-maria/putins-older-daughter-a-specialist-in-biomedical-science-
idUSKCN0SZ1DG20151110#1exov5f4EmMM0wuE.99
• “Exclusive ‘No Tie’ Interview With Head Of The Alfa Banking Holding, Petr
Aven On Business, Childhood And Friends,” Jewish Business News, Nov. 19,
2015, http://jewishbusinessnews.com/2015/11/19/exclusive-no-tie-interview-
with-alfa-banks-president-peter-aven-on-business-childhood-and-friends/
• James Carden, “Trump Attempted a Foreign Policy Makeover Today. Did it

Work?” The Nation, Apr. 27, 2016, https://www.thenation.com/article/trump-
attempted-a-foreign-policy-makeover-today-did-it-work/
• James Kirchick, “Donald Trump’s Russia Connections,” Politico, Apr. 27, 2016,
https://www.politico.eu/article/donald-trumps-russia-connections-foreign-policy-
presidential-campaign/
• Ilya Zaslavsky, “Offshore Is A Sure Thing,” Khodorkovsky, June 14, 2016,

https://webcache.googleusercontent.com/search?q=cache:rF85g61v3FEJ:https://w
ww.khodorkovsky.com/offshore-is-a-sure-thing/+&cd=7&hl=en&ct=clnk&gl=us
• Franklin Foer, “Was a Trump Server Communicating with Russia?”, Slate, Oct.
31, 2016,
http://www.slate.com/articles/news_and_politics/cover_story/2016/10/was_a_serv
er_registered_to_the_trump_organization_communicating_with_russia.html.
• Ilya Zaslavskiy Comments, Nov. 2, 2016,

https://m.facebook.com/zaslavskiy/posts/10155483460048916
• Liz Spayd, “Trump, Russia, and the News Story That Wasn’t,” N.Y. Times, Jan. 20,
2017, https://nyti.ms/2jHyede
• “Lavrov’s Son-In-Law Became Owner of the Largest Pharmaceutical Distributor

in Russia,” Crime Russia, Feb. 2, 2017, https://en.crimerussia.com/gromkie-
dela/lavrov-s-son-in-law-became-owner-of-the-largest-pharmaceutical-
distributor-in-russia/
• Alec Luhn, “The ‘Darth Vader’ of Russia: meet Igor Sechin, Putin’s Right-Hand
Man,” Vox, Feb. 8, 2017, https://www.vox.com/world/2017/2/8/14539800/igor-
sechin-putin-trump-sanctions-oil-rosneft-tillerson-secretary-of-state-kremlin
• “Vinokurov steps down as A1 President to head own investment company,”

Interfax.com, May 15, 2017, http://www.interfax.com/newsinf.asp?id=754010
37
• Stephanie Kirchgaessner, “Lobbyist for Russian Interests Says He Attended

Dinners Hosted by Sessions,” June 15, 2017, The Guardian,
https://www.theguardian.com/us-news/2017/jun/15/lobbyist-russian-interests-jeff-
sessions-testimony
• Sam Biddle, “Russian Bank Accused of Trump Connection Tries to Clear Name
By Pressuring U.S. Computer Researcher,” The Intercept, Oct. 26, 2017,
https://theintercept.com/2017/10/26/russian-bank-accused-of-trump-connection-
tries-to-clear-name-by-pressuring-u-s-computer-researcher/
• Amy Knight, “Why Mueller Named a Russian Oligarch in Court, Daily Beast,
Apr. 6, 2018, https://www.thedailybeast.com/is-muellers-eye-on-some-russian-
oligarchs
• Rafael Saakov, “US Think Tank Takes Heat for Hosting Putin-Linked Oligarchs,”
VOA News, May 23, 2018, https://www.voanews.com/usa/us-think-tank-takes-
heat-hosting-putin-linked-oligarchs
• Damir Marusic & Karina Orlova, “The Great Oligarch Whitewash,” The American
Interest, May 30, 2018, https://www.the-american-interest.com/2018/05/30/the-
great-oligarch-whitewash/
• Jason Leopold & Anthony Cormier, “Here is the Money Trail from the Russian
‘Agent’ and her Republican Partner,” BuzzFeedNews.com, July 31, 2018,
https://www.buzzfeednews.com/article/jasonleopold/maria-butina-paul-erickson-
suspicious-bank-money-russia
• Betsy Swan et al., “Exclusive: This is Accused Russian Spy Maria Butina’s
Secrety Money Man in Moscow, Sources Say,” The Daily Beast, Aug. 22, 2018,
https://www.thedailybeast.com/exclusive-this-is-accused-russian-spy-maria-
butinas-secret-money-man-in-moscow-sources-say
• Dexter Filkins, “Was There a Connection between a Russian Bank and the Trump
Campaign?,” The New Yorker, Oct. 15, 2018 (print edition),
https://www.newyorker.com/magazine/2018/10/15/was-there-a-connection-
between-a-russian-bank-and-the-trump-campaign
• Jason Corcoran,“Kremlin to Buy Alfa Bank from Oligarch Fridman,” Intellinews,

Dec. 5, 2018, https://www.intellinews.com/kremlin-to-buy-alfa-bank-from-
oligarch-fridman-153149/
• Special Counsel Robert S. Mueller, III, Report on the Investigation into Russian
Interference in the 2016 Presidential Election, Vols. I & II (March 2019),
https://www.justice.gov/storage/report.pdf
• Angel Au-Yeung, “Russian Billionaire Vs. The U.S. Government: A Look At

Oleg Deripaska’s Puzzling Lawsuit,” Forbes, March 26, 2019,
38
https://www.forbes.com/sites/angelauyeung/2019/03/26/russian-billionaire-vs-
the-us-government-a-look-at-oleg-deripaskas-puzzling-lawsuit/#2f2d7a756a1c
• Will Louch et al., “Russia-Linked Buyout Firm Violates Deal With U.S. National
Security Panel to Sell Stake,” Wall St. J., July 30, 2019,
https://www.wsj.com/articles/russia-linked-buyout-firm-violates-deal-with-u-s-
national-security-panel-to-sell-stake-11564479001
• Donna Ladd & Nick Judin, “Mississippi Lobbyists, Associates in Thick of Trump’s
Ukraine-Russia Web,” Jackson Free Press, Oct. 2, 2019,
https://www.jacksonfreepress.com/news/2019/oct/02/mississippi-lobbyists-
associates-thick-trumps-ukra/
• Gregory L. White, “As Russia Squeezes Big Business, a Tycoon Decides to Pick
a Fight,” Wall St. J., Oct. 28, 2019,
https://www.wsj.com/articles/SB112856247619561303
19. Identify any documents or evidence reflecting or demonstrating that Plaintiffs

had any involvement or participation in an “attempt to interfere in the 2016 U.S. Presidential
election,” as referenced in Paragraph 13.b. of the Affirmative Defenses in the Answer.
ANSWER: Defendants refer Plaintiffs to the answer to Interrogatory No. 18 and to the
documents Defendants have produced.
20. Identify and describe any information, documents, communications, evidence,

or sources relating to how the headline of CIR 112 (“RUSSIA/US PRESIDENTIAL
ELECTION: KREMLIN-ALPHA GROUP COOPERATION”) relates to the contents of
CIR 112, including any evidence of Plaintiffs’ involvement in interference with the 2016 U.S.
Presidential election.
ANSWER: Objection. Defendants object to this Interrogatory’s use of the phrase

“headline of CIR 112,” because it rests on a false premise, namely that CIR 112 has a
“headline.” Because CIR 112 is an intelligence report, not a news article, it does not contain
a “headline.” Defendants also object to this Interrogatory because it is vague and unclear,
as it is not evident what is meant by the request for information “relating to how the
headline [sic] of CIR 112 … relates to the contents of CIR 112.” Defendants also object on
the grounds that they are not the author of CIR 112 and to the extent this Interrogatory asks
for Defendants to speculate as to what Christopher Steele was thinking when he drafted the
report, the Interrogatory improperly calls for speculation.
With respect to the remaining unobjectionable portions of the Interrogatory, Defendants

refer Plaintiffs to Defendants’ Answers to Interrogatories No. 18 and 19.
21. Identify and describe all document retention or destruction policies you have
or had in place during the Relevant Period, including all electronic document, e-mail, and
instant message back-up and deletion policies.
39

information and the identification of documents that are covered by the attorney-client
privilege and the attorney work product doctrine. Defendants also object to this
Interrogatory because it uses a term that is not defined: “Relevant Period.” Defendants
object to the term “you,” because Plaintiffs define “you” to include “persons or entities
acting . . . in concert with” the Defendants, but information in the possession, custody, or
control of persons or entities acting “in concert with” the Defendants is not in Defendants’
possession, custody, or control and the Defendants therefore cannot provide that
information.
As to the non-objectionable portion of the Interrogatory, Defendants provide the following

answer that does not implicate these privileges:
Defendants’ work product for clients is the property of the client. At the end of each
engagement, Defendants return or destroy the work product as directed by the client.
Upon receipt of any request for information or documents from a third party (e.g., a
congressional committee), or upon service of notice of a complaint, Defendants received
and complied with memoranda from counsel, requiring Defendants to preserve documents
related to the subject matter of the requests and litigation.
22. Identify all persons who Defendants intend to call as witnesses at trial, and the
subjects on which each person is expected to testify.
ANSWER: Objection. Defendants object to this Interrogatory because it seeks premature

disclosure of witnesses. Defendants’ counsel have not identified witnesses they intend to
call at trial. Defendants will timely disclose witnesses subject to the Federal Rules, this
Court’s Local Rules, and the Scheduling Order in this Action.
23. Identify (consistent with Instructions H.(v) and (vi)) in Plaintiffs’ Second Set
of Interrogatories any documents responsive to any Interrogatory or Document Request
propounded by the Plaintiffs, or otherwise relevant to any of the issues in this Action, that
were “return[ed] or destroy[ed]” (including work product, memos, source information or
analysis, engagement agreement with Steele or Orbis, etc.) in accordance with the procedure
identified in Response to Interrogatory No. 21.

information and the identification of documents that are covered by the attorney-client
privilege and the attorney work product doctrine. Defendants also object to this
Interrogatory because it is vague and ambiguous, as it does not specify to which of
Defendants’ clients it refers when it says “that were ‘return[ed] or destroy[ed].’”
As to the non-objectionable portion of the Interrogatory, Defendants provide the following

answer that does not implicate the claimed privileges:
Aside from the following three items, Defendants cannot recall what specific, individual
documents they had that would have been responsive to any Interrogatory or Document
Request or relevant to any of the issues in this Action and that “were ‘returne[ed] or
40
destroy[ed]’ in accordance with the procedure identified in Response to Interrogatory No.

21.”
• Defendants had a copy of an engagement letter with Orbis and/or Christopher

Steele. As set forth in Answer to Interrogatory No. 21, such document was the
property of the client and at the end of the engagement, Defendants regularly
destroy or return documents to clients. Defendants do not recall whether the
document was returned to the client or destroyed, and they do not recall the specific
date in November or December 2016 when the document was returned or
destroyed. Peter Fritsch can testify regarding these matters.
• Defendants had a copy of a memorandum responsive to Document Request No. 26.

As set forth in Answer to Interrogatory No. 21, such document was the property of
the client and at the end of the engagement, Defendants regularly destroy or return
documents to clients. Defendants do not recall whether the document was returned
to the client or destroyed, and they do not recall the specific date in November or
December 2016 when the document was returned or destroyed. Peter Fritsch can
testify regarding these matters.
• Defendants had a communication from Orbis transmitting an encrypted copy of

CIR 112, but they do not recall whether such communication was an e-mail or other
form of communication. As set forth in Answer to Interrogatory No. 21, such
document was the property of the client and at the end of the engagement,
Defendants regularly destroy or return documents to clients. Defendants do not
recall whether the document was returned to the client or destroyed, and they do
not recall the specific date in November or December 2016 when the document was
returned or destroyed. Peter Fritsch can testify regarding these matters.
Dated: May 18, 2020 By: /s/ Joshua A. Levy
Joshua A. Levy (D.C. Bar No. 475108)

Rachel M. Clattenburg (D.C. Bar No. 1018164)
LEVY FIRESTONE MUSE LLP
Tel: (202) 845-3215
Fax: (202) 595-8253
jal@cunninghamlevy.com
Counsel for Defendants
41
I HEREBY CERTIFY that on May 18, 2020 the foregoing Answers to Interrogatories were
served via email on counsel of record:
Alan S. Lewis, Esquire

2 Wall Street
New York, NY 10005
Tel: (212) 238-8647
Lewis@clm.com
Kim Hoyt Sperduto, Esquire

SPERDUTO THOMPSON PLC
1133 Twentieth Street, NW
Second Floor
Tel: (202) 408-8900
ksperduto@sperdutothompson.com
/s/ Joshua A. Levy_______

Joshua A. Levy
43
EXHIBIT G
Neutral Citation Number: [2020] EWHC 1812 (QB)
Case No: QB-2018-006349

IN THE HIGH COURT OF JUSTICE
QUEEN'S BENCH DIVISION
MEDIA AND COMMUNICATIONS LIST
Royal Courts of Justice

Strand, London, WC2A 2LL
Date: 08/07/2020
Before:
MR JUSTICE WARBY
---------------------
Between:
(1) Petr Aven

(2) Mikhail Fridman
(3) German Khan Claimants
- and -
Orbis Business Intelligence Limited Defendant
---------------------
---------------------
Hugh Tomlinson QC and Kirsten Sjøvoll (instructed by CMS Cameron McKenna Nabarro
Olswang LLP) for the Claimants
Gavin Millar QC and Robin Hopkins (instructed by Reynolds Porter Chamberlain LLP)
for the Defendant
Hearing dates: 16 - 19 March 2020

---------------------
Approved Judgment
Judgment Approved by the court for handing down. Aven v Orbis Business Intelligence [2020] EWHC 1812 (QB)
INDEX
Section Paragraphs
Introduction 1-9
The Trial 10-11
The overall legal framework 12-17
Issues on liability 18-19
The Personal Data Issue 20-45
A narrative 46-62
The Legal Purposes Issue
The relevant provisions 63-73
The parties’ contentions 74-78
Assessment 79-104
The National Security Issue
The law 105-112
The facts 113-118
Submissions 119-122
Assessment 123-129
The Fairness Issue
Conclusions 130
Reasons 131-144
The Accuracy Issue
The issues in dispute 145-149
Fact or opinion? 150-151
Inaccurate or misleading? 152-174
Accurate recording? 175-176
Reasonable steps? 177-187
Remedies 188-203
Summary of Conclusions 204
48. Orbis worked with Fusion on a handful of occasions between 2010 and 2016.
Sometimes, Orbis would engage Fusion, and on other occasions Fusion would engage
Orbis.
49. In about late May 2016, Mr Simpson, on behalf of Fusion, contacted Mr Steele with
instructions to investigate Donald Trump and his alleged links with Russia and Russian
officials, specifically President Putin. Mr Trump was then the presumptive Republican
candidate for the Presidency. Fusion was acting on the instructions of a Washington
DC law firm called Perkins Coie, which in turn was acting on the instructions of one or
more persons or bodies at the top of the Democratic Party (“the Ultimate Client”).
50. Pursuant to Fusion’s instructions, between June 2016 and the Presidential Election on
8 November 2016, Orbis produced the 16 memoranda that were eventually published
in the Buzzfeed Article. The first memorandum was dated 20 June 2016. Four more
were prepared in July, four in August, three in September, and four in October 2016.
For this work, Orbis was paid a retainer of £100,000, in five monthly instalments. Orbis
invoiced and was paid by Fusion.
Disclosures
51. Orbis, through Mr Steele, admit or maintain that they made or authorised disclosures
of memoranda from the Steele Dossier on the following occasions:
(1) On 5 July 2016, Mr Steele and Mr Burrows met FBI officials at Orbis’ offices
in London. Mr Steele provided the FBI with the reports which Orbis had
prepared by that point. This did not include Memorandum 112. Mr Steele made
a note of this meeting (“the FBI Note”).
(2) In August 2016, Mr Steele provided the FBI with all the memoranda prepared
to date. These did not include Memorandum 112. He promised to provide further
reports.
(3) On 14 September 2016, Memorandum 112 was delivered to Fusion. Orbis has
dubbed this “the Fusion Disclosure” and I shall adopt that label.
(4) In September 2016, to the FBI. Orbis’ pleaded case is that it delivered a copy
of Memorandum 112 to “a senior US national security official” in or around
September 2016. Mr Steele’s evidence is that within a few days of the Fusion
Disclosure, that is to say in about mid-September 2016, he provided a copy of
Memorandum 112 to the FBI. That is disputed.
(5) In November 2016, Mr Steele made three further disclosures of Memorandum

112 and other memoranda from the Steele Dossier, to politicians and
government officials: -
a) Strobe Talbott, a former US Deputy Secretary of State;
b) an unnamed individual described by Mr Steele as a “UK government

national security official”; and
c) David Kramer, a former US Assistant Secretary of State for Democracy,

Human Rights and Labor, in the Bush Administration.
52. At some point between late November 2016 and 10 January 2017, Mr Kramer gave
Buzzfeed access to the Steele Dossier, thereby causing or contributing to the publication
of the Buzzfeed Article.
53. In December 2016, Mr Kramer asked Mr Steele to agree to him discussing the Steele
Dossier with a senior US national security official, Celeste Wallander. Mr Steele
maintains that he did not give or withhold consent, but in any event did not authorise
the disclosure of Memorandum 112 by Mr Kramer to Ms Wallander. That has not been
challenged, so I do not need to address any disclosure that may have been made by Mr
Kramer to Ms Wallander.
54. Orbis has given a collective label to four disclosures of Memorandum 112: Mr Steele’s
alleged disclosure to the FBI in September 2016, and the three disclosures of November
2016 for which he admits responsibility. Orbis calls these “the National Security
Disclosures”. It is helpful to have a collective label, and I shall adopt this one, but
without adopting any tendentious overtones it may possess. It is not disputed that Mr
Steele’s motivation in making these disclosures was to protect the national security of
the UK and/or the US. The question is whether that purpose requires that the data in
question be exempted from the relevant aspects of the DPA.
Responsibility for disclosure
55. Orbis accepts responsibility for the Fusion Disclosure and the National Security
Disclosures. The only issue in dispute about those disclosures is whether Orbis did in
fact disclose Memorandum 112 to the FBI in September 2016.
56. Orbis denies responsibility for any other disclosures, or any other processing activities
of other controllers. That includes any disclosures to or publications by Buzzfeed, or
other media organisations, which Orbis maintains are the responsibility of the media or
of other individuals.
57. In his opening submissions, in cross-examination, and in his argument on remedies, Mr

Tomlinson raised the question of whether Orbis was responsible for disclosures of
Memorandum 112 made by Mr Kramer to the Washington Post and to Buzzfeed, and
thereby responsible for media publication of the personal data in Memorandum 112. In
cross-examination, Mr Tomlinson showed Mr Steele the transcript of Mr Kramer’s
deposition on 13 December 2017 in Gubarev v Buzzfeed Inc., a case brought in the US
District Court for the Southern District of Florida. Mr Kramer gave evidence, in those
proceedings, that Mr Steele knew that Mr Kramer was going to provide a copy of
Memorandum 112 to the Washington Post. As for Buzzfeed, Mr Tomlinson secured an
admission that Mr Steele had put Mr Kramer in touch with Ken Bensinger of Buzzfeed.
He put it to Mr Steele that he did that when he knew, or should at least have foreseen,
that Mr Bensinger would ask for the dossier and that Kramer would provide it.
58. I was a little surprised by this aspect of the claimants’ case, as I had not detected any
clear averment to this effect in the Particulars of Claim. There is mention there of
disclosure to “third parties” including “the media” but no details, and no allegation that
Orbis disclosed to Buzzfeed, or the Washington Post, or that it caused or authorised any
such disclosure. The Particulars of Claim state that details of the identity of the
recipients of Memorandum 112, other than Fusion, would be added after disclosure
and/or the provision of further information by Orbis. But this was never done. Nor am
I aware that any notice was given of an intention to rely on the Kramer transcript as
hearsay evidence at the trial. In any event, the claimants have not persuaded me that
any disclosures of Memorandum 112 by Mr Kramer represented the processing of data
by or on behalf of Orbis.
59. , and the documentary evidence

and cross-examination make it clear that, in and after late September 2016 he was
heavily and enthusiastically involved in doing so. His explanation is that he wished to
But oral disclosures are not caught by the DPA: Scott v LGBT Foundation
[2020] EWHC 483 (QB) [55] (Saini J). And encouraging the media to report on a
story, and giving them background information about it, are not the same thing as
providing or authorising the provision of documents for that purpose. The high point of
this a Mother Jones dated 31
October 2016, for which Mr Steele has admitted he was a source. That article states that
the authors have reviewed some of the Orbis reports, and appears to quote from them.
The OIG report corroborates this, suggesting that a Mother Jones journalist provided
to the FBI (footnote 259). Cross-examined, however, Mr
Steele insisted that he had not given or read any of his reports to Mother Jones. He has
been clear and consistent in his denials that he provided any journalist with a copy of
Memorandum 112, or any other part of the Dossier, or authorised others to do so. In
paragraph 57 of his revised first witness statement he said he did not disclose or discuss
the content of Memorandum 112 with the media, and did not intend, authorise or
envisage that
Second Claimants would become more widely disseminated. In paragraph 58 he
specifically denied giving permission for the provision of a copy of the Dossier to Ken
Bensinger. That was not directly challenged.
60. The deposition of Mr Kramer is not a satisfactory basis for an invitation to reject Mr
evidence and find Orbis liable for disclosure and publication of Memorandum
112 made by others. Besides the procedural shortcomings I have identified, the
deposition is provided to me shorn of its context. I am told nothing else about the
Gubarev v Buzzfeed litigation, and very little about Mr Kramer except that (as is
obvious) he had a clear motive for tailoring his evidence. In any event, knowledge that
a person intends to make a disclosure is not enough to bring home liability. And the
substance of evidence, so far as Buzzfeed is concerned, is this. Mr Steele
asked him to meet Mr Bensinger, but without asking him to provide a copy of the
Dossier; Mr Kramer did not provide Mr Bensinger with a copy, but left him in a room
with the memos for 20-30 minutes, on the agreed basis that Mr Bensinger would use
the time to read them; in that period, Mr Bensinger took photos of the documents,
consent; and Mr Kramer only found out about this
when he saw the Buzzfeed Article, and did not intend the Dossier to be published. Mr
Tomlinson, having effectively called Mr Kramer as his witness, could not and did not
question this account. It undermines the case he sought to advance.
61. On the basis of this evidence, I see no room for concluding that Mr Kramer made a
disclosure to the Washington Post or Buzzfeed of the personal data contained in
Memorandum 112 which amounted to processing of those data by or on behalf of Orbis,
still less that the publication of those data by the Washington Post and Buzzfeed
represented, or even resulted from, processing by or on behalf of Orbis. A data
(b) is satisfied on the application of a data subject that

personal data of which he was the data subject and which have
been rectified, blocked, erased or destroyed were inaccurate,
it may, where it considers it reasonably practicable, order the
data controller to notify third parties to whom the data have been
disclosed of the rectification, blocking, erasure or destruction.”
The parties’ contentions
74. Orbis’ case is that the creation of Memorandum 112, and the Fusion Disclosure which
followed, were necessary, in the sense I have identified, for the carrying out of
instructions Orbis received from Fusion, at the instigation of Perkins Coie, shortly after
29 July 2016. The purpose of those instructions, it is said, was
“to facilitate an understanding of the extent to which Alfa

worked with President Putin, given concerns about (i) potential
interference by the Russian state in the US Presidential election
process and (ii) suspected communications between the servers
of Alfa Bank and Trump Tower.”
75. It is submitted that Mr Steele understood that the intelligence he gathered would be
used to advise the Ultimate Client on the prospect of legal proceedings and, if necessary,
deployed in such proceedings to challenge the eventual outcome of the Presidential
Election. Orbis’ instructions, and thus the Fusion Disclosure, were reasonably
necessary to enable such advice to be given and for decisions to be made about the legal
implications of those matters and/or to assist the Ultimate Client with those
implications. Specifically, it is said that the Fusion Disclosure was necessary as a step
towards establishing whether any rights under electoral law might flow from the matters
recorded in the memoranda. That brings the case within the concept of “establishing
legal rights” in s 35(2).
76. This has the following consequences, submits Mr Millar:-
(1) The Fourth Principle “falls away”. Memorandum 112 was an intelligence
report, the fruit of investigative activities. It was a “piece of the mosaic” on
unresolved questions which were the subject of continuing enquiry, as part of a
wider exercise of assessing the alleged links between Russia and the Trump
campaign. That was a matter of some urgency, given the election on 8 November
2016. In all these circumstances, compliance with the duty of accuracy would
have been inconsistent with the purposes for which Memorandum 112 was
compiled and disclosed.
(2) The Notice Requirements also “fall away”. The purposes of the Fusion
Disclosure, and the duties of confidence owed to clients in such contexts, were
plainly inconsistent with a requirement to give the data subjects advance notice.
(3) Although the duty to comply with a Schedule 2 condition and (on the basis of
my findings) a Schedule 3 condition remains in place, that duty is discharged by
virtue of the very purposes that justify the application of the Legal Purposes
Exemption.
81. This task faces some obstacles. There were a number of participants who were directly
involved, and could have shed light on the questions for determination, but I have
evidence from only one of them: Mr Steele. He has given two very different versions
of events, which are mutually inconsistent in a number of respects. This was, on any
view, an intelligence-gathering exercise, inherently unlikely to be heavily documented.
Mr Steele kept few records, and most of these he did keep have been lost or destroyed.
One contemporaneous record of relevance has survived: the FBI Note, recording the
substance of a meeting on 5 July 2016. But this only helps with some relatively minor
aspects of the story. There is little other documentation that throws any light on the
facts. Much of what there is consists of press cuttings, from several months after the
events to which they relate, containing hearsay from anonymous or unidentified
sources. Against that background I take a cautious approach, but find the following
relevant facts.
82. Orbis’ engagement by Fusion was first mooted at a meeting between Mr Simpson and
Mr Steele at Carluccio’s restaurant at Heathrow Airport in late May 2016, and
confirmed by Mr Simpson in a telephone conversation between them about a week
later. I accept Mr Steele’s evidence: the words used were to the effect that Orbis was to
collect intelligence from sources on Trump-Russia issues and interference in the US
Presidential campaign, which would be “fed to” a “respectable” law firm based in
Washington DC which was Fusion’s client. The initial engagement was for one month
on a retainer of $20,000. The retainer was in due course increased. But there was no
documentation, at that time or later. The law firm, though not named at the time, was
Perkins Coie. As was apparent to Mr Steele, the law firm had a principal: the Ultimate
Client.
83. Mr Steele’s evidence is that he now believes the Ultimate Client was the Democratic
National Committee. Mr Millar submits that the Ultimate Client was the Clinton
election campaign, “Hillary for America”. This is in line with the FBI Note of 5 July
2016, which records Mr Steele telling the FBI that Orbis had been instructed by Mr
Simpson of Fusion and “Democratic Party Associates” but that “the ultimate client were
(sic) the leadership of the Clinton presidential campaign”. The FBI Note also indicates
that Mr Steele had been told by that stage that Mrs Clinton herself was aware of what
Orbis had been commissioned to do.
84. I have little reliable evidence as to who exactly was the Ultimate Client, but I have
enough to find that Perkins Coie were instructed by one or more people or organisations
within the upper echelons of the Democratic Party, concerned to ensure Hillary
Clinton’s election as President. I also find that Mr Steele knew this much from early
June 2016, at least. I do not believe it is necessary, or relevant, to go further. I shall
continue to refer to the Ultimate Client, without identifying who they were.
85. It would be naïve and unreal to suppose that the Ultimate Client, when instructing
Perkins Coie, did not have political aims. The role and position of the Ultimate Client,
the relationship in which that client stood to Mr Trump, and the nature of the
instructions, make it obvious that they did. But it does not follow that there was no
legal purpose. In my judgment, on the evidence before me at this trial, there was one,
and it applied to the commissioning of the Dossier as a whole, including the creation
and delivery of Memorandum 112. The purpose was obtaining legal advice.
86. The Ultimate Client’s instructions were not given to Orbis or to Fusion. They were
given to a law firm, and passed on by that firm to the investigative organisations. The
plan from the outset was that the output of the investigative activities that Perkins Coie
commissioned would then (to use Mr Steele’s words) be “fed back” to the law firm.
This raises the question of why a law firm was involved at all. In cross-examination,
Mr Tomlinson put it to Mr Steele that Perkins Coie were effectively the “legal arm” of
the Democratic Party. He accepted that, but I cannot give any real weight to this rather
vague proposition. Nor can I uphold the further proposition about the firm that was put
by Mr Tomlinson to Mr Steele:
“they instruct investigators to obtain material about political

opponents in a privileged setting so it can then be used for
campaigning by the Democratic Party”.
There is no evidence before me that could sustain that suggestion.
87. My conclusion is that Perkins Coie were approached by the Ultimate Client and given
the instructions they were with a view to obtaining information for the purpose (though
not the exclusive purpose) of taking legal advice on its legal implications and what, if
any, legal steps could be taken as a result. On the balance of probabilities, Perkins
Coie’s sole or dominant purpose in commissioning the Dossier was to obtain
information for the purpose of providing legal advice. These are not mere assumptions
nor are they speculation, as suggested by Mr Tomlinson. They are reasonable
inferences from the fact that a law firm was instructed at all, and from such of the
evidence as I accept about the nature of the firm, its dealings with Fusion and Orbis,
and the individual lawyers who were involved.
(1) It was in the latter part of July 2016 that Mr Steele first learned the identity of
the law firm, the existence and role of which had been known to him from the
outset. He was given the name by Mr Simpson and looked up the firm’s website.
It is on that basis that he accepted the proposition that the firm was “the legal
arm” of the Democratic Party.
(2) After this, on about 29 July 2016, Mr Steele and Mr Simpson met a partner from
the firm’s Privacy and Data Security Practice, named Michael Sussman. Mr
Sussman mentioned allegations about suspicious server activity involving Alfa
Bank and the Trump organisation.
(3) At this meeting, Mr Steele was told that the team instructing him and Fusion
included another partner, Marc Elias. Mr Elias was General Counsel to the
Clinton Presidential campaign, and an electoral law specialist. The firm’s
website suggests that he is one of the foremost electoral litigators in the United
States. Mr Steele gave evidence suggesting that Mr Elias was or may have been
in an adjacent room at the time of this meeting. I am not confident of that, and
make no finding on it. I do find that Mr Elias was not at the meeting.
(4) It was shortly after this meeting that Mr Simpson gave instructions by telephone
for Orbis to produce a Memorandum on Alfa Bank’s links with the Kremlin.
Memorandum 112 responded to those instructions, and was prepared over the
four to six weeks immediately preceding the Fusion Disclosure.
(5) After the Fusion Disclosure Mr Steele had a second meeting with Perkins Coie,
at which its contents were discussed. This was on or about 22 September 2016.
(6) At some point in his dealings with Perkins Coie, Mr Steele was told by them
that they wanted to obtain information and monitor irregularities in the election
campaign.
88. These findings represent an acceptance of evidence given by Mr Steele in his second
witness statement dated 15 March 2020, and on oath at the trial. They mean that the
account given in first witness statement was significantly mistaken. That statement said
that Mr Steele had one meeting with the lawyers in late July, then another which took
place on 11 September 2016, which is when he was instructed to produce Memorandum
112. This is a big change of story, and that obviously casts doubt on the revised account.
The new account comes several years after the events.
89. I have given careful thought to this, but I accept Mr Steele’s revised account. It is
coherent, more probable than the original one, and there is an explanation, supported
by documents. Mr Steele says that when preparing to give evidence he was prompted
to reconsider his original account by noting something in the December 2019 Report of
the Office of the Inspector General (“OIG”). This recorded that Mr Steele had met a
Department of Justice official on 23 September 2016. Examination of his passport
shows that he entered the USA on 29 July and 21 September 2016. A credit card
statement shows he flew out of London on 21 September, and on 24 September paid
for a stay at the Hilton Hotel in Washington DC. All this was at odds with a meeting on
11 September.
90. As for the late July meeting, I have taken account of Mr Tomlinson’s challenge to the
suggestion that Perkins Coie briefed Mr Steele on suspicious server activity at that time.
Mr Tomlinson relied on two media articles, one by Franklin Foer in Slate, dated 31
October 2016, entitled “Was a Trump Server Communicating With Russia”, and
another by Dexter Filkins in The New Yorker dated 15 October 2018, entitled “Was
there a connection between a Russian Bank and the Trump Campaign?” Mr Steele was
cross-examined to the effect that these articles were inconsistent with his evidence. It
was put to him that there was not a shred of evidence that, in late July 2016, anyone
had reached the conclusions that, according to Mr Steele, were put to him by Perkins
Coie. These are articles based on anonymous sources which sought to tell the story of
an emerging “scandal”, months or years after the event. They both suggest that
computer scientists were investigating the possibility of Russian hacking of the
Republican Party from as early as June 2016. The articles were not aimed at, and did
not confront, the propositions advanced by Mr Steele in his evidence to me. They do
not profess to set out a minutely detailed chronology. Neither the authors nor their
sources have given evidence or addressed the specifics of Orbis’ case in writing. I do
not regard this anonymous second-hand hearsay as a sound basis for rejecting Mr
Steele’s evidence.
91. As for the prospect of taking legal action, Mr Tomlinson is right: there is no evidence
of any legal action being taken, or of any thought being given to it, or as to what might
have been done, legally. I can however draw inferences. My conclusion is that the
possibility of litigation may well have been in the minds of the Ultimate Client and
Perkins Coie at the outset, in the sense that it would have been devoutly hoped for, and
would have been pursued if favourable advice had been given. By the time of the
111. The structure and the language of s 28 are both different from those of the Legal
Purposes Exemption. It might be said that the differences are more semantic and
apparent than real. There are however two points about the language which are, in my
judgment, significant for present purposes.
(1) The first is that the s 28 exemption applies to personal data and not to a
disclosure. This is a broad exemption which protects, or is capable of protecting,
specified kinds or categories or descriptions of information rather than
disclosures that take place for certain kinds of purpose. It can be a class-based
exemption. This is reflected in s 28(3), which provides that a Ministerial
(2) Secondly, the test imposed by s 28 is not whether the application of a principle
or provision would be a disclosure
a purpose for the
specified purpose.
112. The concept of necessity is a familiar one, much used, much litigated and well
understood in the context of human rights and data protection law.
term used in , namely Article 13(1)(a) of the Directive which
provides that
Member States may adopt legislative measures to

restrict the scope of the obligations ovided for in
restriction constitutes a
It would have been easy, indeed natural, to use the same word in s 28(1), but Parliament
chose a different term. The Court should treat that choice as significant. It cannot
The intention I attribute to
Parliament is to impose a more exacting test, limiting the scope of this broad exemption
to cases where it is judged to be indispensable to the safety and well-being of the nation
that certain personal data be exempt from a Data Protection Principle or other DPA
provision. If this analysis is correct, it follows that there may be cases in which a
disclosure of personal data is reasonably necessary for the purposes of national
security but the purpose of safeguarding national security does not require that the
personal data be exempt from any of the specified DPA provisions.
The facts
113. I have set out on the facts at 51(2)-(3), (4) and (5) above. Mr Steele has
given evidence supporting that case. For the most part, he was not challenged about
what took place. On the one disputed issue, namely whether Mr Steele provided the
FBI with a copy of Memorandum 112 in September 2016, within a few days of the
Fusion Disclosure, I find in favour of Orbis.
(1) The FBI Note indicates that the meeting of 5 July 2016 was one at which Mr
Steele volunteered disclosures to the FBI. It records that the FBI officials were
, , and asked
when there might be follow-up opportunities. One of the officers said he would
circulate
The note was made on 8 July 2016, apparently for internal purposes. It
consider it likely to be an
accurate reflection of what actually happened.
(2) In oral evidence he elaborated, by explaining that his understanding in July 2016
was that the FBI officer he met had cleared his lines with the Assistant Secretary
of State, Victoria Nuland. He was challenged over that, which was not in his
statement, but I accept it.
(3) It is an agreed fact that, by 31 July 2016, the FBI had opened an investigation
into allegations of foreign interference with the US Presidential Elections, under
the name Crossfire Hurricane .
(4) It is an undisputed fact, and I accept, that Mr Steele provided further

memoranda to the FBI in August 2016. I accept his evidence, which has not
been contradicted, that he did so, without seeking permission from his
principals, with all the intelligence
, he considered the
intelligence to be important, and considered it his duty to the Crown to seek to
ensure that the intelligence was brought to the attention of appropriate
authorities and thoroughly investigated.
(5) As already mentioned, by late September, Mr Steele was enthusiastically
(6)
September is consistent with the pattern of these other items of evidence.
(7) There is documentary evidence of a meeting on 11 October 2016, between Mr

Steele, another Orbis representative, and Kathy Kavalec of the State Department
at which
discussed. Mr Steele was, at this stage, still regarded by the FBI as a covert
human source. He told me that it was clear to him at this meeting that the
Memorandum was being discussed between the FBI and State Department. A
State Department note of this meeting provides some support for that evidence.
It refers to t that are being tracked by Orbis. One
etween Trump via Manafort and the Kremlin
the note contains the following:
Peter Aven of Alfa Bank has been the conduit for secret
communications between the Kremlin and Manafort;
messages are encrypted via TOR software and run
between a hidden server managed by Alfa Bank (see
contacts with Putin go back to St Petersburg, when Putin

made $100M in the oil-for-food business while Aven was
Minister of Foreign Trade.
This further demonstrates the US

authorities with information of the kind contained in Memorandum 112, and
suggests that the State Department already had a separate paper on the topic of
communications via a hidden server managed by Alfa Bank.
(8) The claimants rely on three footnotes to the OIG Report. Footnote 231 identifies
Memorandum 112 as one of a four that Steele did not furnish to the
FBI, which range in d Footnote 259 states
November 6, 2016, from a Mother Jones journalist through then FBI Counsel
. Footnote 319 refers to the provision of (among others)
Memorandum 112 to the FBI by Senator John McCain, on 9 December 2016. It
from Steele.
(9) There is no evidence to explain these footnotes. The sources on which they are
based have not been identified to me. Again, I am asked to prefer multiple
hearsay evidence from unidentified sources to that of a witness, supported to
some extent by a contemporaneous document. In my judgment, it is unlikely
that Mr Steele failed to provide the FBI with a report on matters which he plainly
considered to be important, and which he was briefing journalists about and
discussing with the State Department within a month of making the Fusion
Disclosure. On the balance of probabilities, the footnotes are mistaken insofar
as they suggest that Mr Steele did not provide Memorandum 112 to the FBI.
That could be because its provision was somehow not recorded, or that the
records were not identified in the course of preparing the OIG Report, or for
some other reason.
114. This means that there are four National Security Disclosures for consideration. My
findings, about those disclosures are as follows.
September 2016: The FBI
115. The memorandum was volunteered by Mr Steele, rather than requisitioned or demanded
by the FBI. to make the disclosure. He
probably did it by secure email, this being the method he used to provide the FBI with
other Dossier reports. The State Department note indicates that a record was made at
that department. The evidence does not suggest, however, that the FBI or the State
Department took any particular interest in the claimants, or Alfa, or Memorandum 112.
The best explanation for the footnotes to the OIG report may be that the FBI did not
regard the contents of Memorandum 112 as of high importance.
Early November 2016: Strobe Talbott
116. In early November, Mr Steele personally provided a copy of the Dossier, including
Memorandum 112, to Mr Talbott first
witness statement, is this. Mr Talbott, who was at the time the President of the
Brookings Institution and a member of the Council on Foreign Relations, approached
Mr Steele. He said that he was due to meet a group of individuals at the State
Department
Mr Steele agreed. He did so on the understanding that Mr Talbott had been speaking to
the US Secretary of State John Kerry, and Ms Nuland, who knew of the Dossier and its
broad content; and that the individuals whom Mr Talbott was due to meet included the
then US Deputy Secretary of State, Tony Blinken.
Mid-November 2016: the UK government national security official
117. By mid-November, Mr Steele had come to the view that the intelligence he was
receiving had national security implications for the UK, which he thou
He considered he owed
a continuing duty to report to his former empl
On or about 15 November 2016, he conferred with a former
colleague, without providing copies of his memoranda or discussing the content. They
, for
the purpose of helping safeguard UK national security. He therefore contact
assessment that he should report the relevant intelligence. The official requested and
Mr Steele provided copies of the memoranda, including Memorandum 112.
Late November 2016: David Kramer
118. On 28 November 2016, Mr Steele met Mr Kramer. Shortly afterwards, Mr Steele

arranged for Fusion, in the person of Mr Simpson, to print copies of his memoranda
and provide them to Mr Kramer. The background to this is e
first witness statement, and can be summarised as follows.
(1) Orbis had a relationship with a former British diplomat, Sir Andrew Wood, a
Russianist, a former Ambassador to Russia, and a friend of Mr Steele. In early
November, Mr Steele confided the substance of his reports to Sir Andrew.
(2) Sir Andrew then met David Kramer at an international security conference,
where they discussed mutual concerns about Mr
Kramer was at that time the aide to Senator McCain. Senator McCain was Chair
of the Senate Armed Services Committee.
(3) Mr Kramer introduced Sir Andrew to Senator McCain, who asked him to
about Russian interference in the US presidential election arising from the

intelligence we had gathered and give him sight of this intelligence on a
confidential bas .
(4) When that meeting took place, on 28 November, Mr Kramer said that he
considered the intelligence raised issues of potential national security
importance to the US. Mr Steele showed him, and they discussed, the reports
that had been prepared by then, including Memorandum 112.
(5) After Mr Kramer had returned to the US, he asked for copies. Mr Steele arranged
this, understanding the purpose to be the provision of those copies to Senator
McCain by Mr Kramer, in person, with a view to taking appropriate action, such
as discussion with senior Congressional colleagues.
concluded that this was in fact the case. But I do not consider this to be a satisfactory
basis on which to reject Mr Aven’s evidence to me.
Accurate recording?
175. The evidence on this and the next issue comes of course from Mr Steele. His account
is that the Dossier comprised intelligence obtained from 3 sources and approximately
20 sub-sources, all of whose identities were known to him. His contacts were with the
sources. He met the sources and, during the meeting, made a manuscript note of what
he was told. Within a day or so, he would compile a memorandum. He kept the
manuscript notes for as long as necessary for that purpose, then destroyed them.
Memorandum 112 was based on intelligence provided by a single source and a single
sub-source. Mr Steele had a 2-hour meeting with the source, and wrote up the
memorandum shortly after, destroying the manuscript notes.
176. Mr Tomlinson invites me to find that Orbis has failed to prove that Memorandum 112
accurately records the information provided by the source. He relies on passages in the
OIG report, that record that the source told that investigation that Mr Steele had
“misstated and exaggerated his statements in multiple sections of his reporting” and
that had made it clear that it was “just talk”. The submission is that Mr Steele failed
convincingly to counter these criticisms. I do not think that is the right approach. The
question, rather, is whether the hearsay passages from the OIG report, summarising
aspects of what the source said to the Department of Justice in January and March 2017,
undermine the reliability of Mr Steele’s written and oral evidence to me about
Memorandum 112. None of the statements goes directly to the content of Memorandum
112. It is clear that the source may have had an axe to grind. I accept Mr Steele’s account
and find that the memorandum records accurately what he was told by the source.
Reasonable steps?
177. Mr Steele describes in his witness statement the steps he took “to ensure as far as
possible the reliability” of the content of the memoranda in the Dossier, including
Memorandum 112:
“I assessed the intelligence I received having regard to what I

knew of the sources and sub-sources and their roles, my
knowledge of the structure of the Russian political system and
its inter-connections with business, and the credibility of their
story. I asked others about the individual source or sub-source
and their story, and I cross-referenced the information I received
against open source data where possible. I asked myself whether
the appearance of the information (for example, whether it
seemed sensationalist, had any discrepancies or any seemingly
misleading information etc), the access of the individual, and the
story itself added up and tallied with the intelligence being
received from others, and was consistent with my own
knowledge and experience. I did not take what was said at face
value but instead looked at the open source data pertaining to the
individuals involved, other reporting, including that provided by
other sources, and tried to find out whether other government
and intelligence institutions internationally had any relevant
number of allegations about them. It is said, for instance that “It has been alleged that
the First and Second Claimants were involved in trafficking heroin from Burma to East
Germany…”. It is said that the New York Times has “reported on allegations of
criminality, including drug dealing/running, corruption and embezzlement”. Reliance
is placed on the judgment of Judge Bates, which refers to media reports. Mr Millar
argues that the claimants’ complaint that Memorandum 112 represented a serious
intrusion into their rights is “unsustainable” in the light of this material.
201. These submissions are contrary to established principle. A defendant can mitigate
damages by proving that the claimant had an existing bad reputation, but (1) evidence
is only admissible in respect of the “relevant sector” of the claimant’s reputation; proof
of a bad reputation for something different is irrelevant; (2) bad reputation in the
relevant sector cannot be proved by relying on specific acts of misconduct or third party
reports, rumours, newspaper cuttings or media reports of bad behaviour: see Barron v
Vines [21(5)-(6)], [23-24]. Those passages show that these rules have been firmly
established since 1858, and were reaffirmed by the House of Lords in 1964, and the
Court of Appeal in 2001. The rule against mitigation of damages by reliance on other
publications was reaffirmed once more by the Supreme Court in 2019: see Lachaux v
Independent Print Ltd [2019] UKSC 27 [2020] AC 612 [22], [24] (Lord Sumption).
202. That said, the “publication” I am concerned with is limited. I have no evidence that the
opinion of any of the recipients was of particular concern to these claimants, or that the
recipients took any particular steps that led to identifiable harm. This is one of those
cases in which the fact and content of a reasoned judgment should have a moderating
effect on the sum that is appropriate by way of vindication.
203. My conclusion is that I should award each of the first and second claimants
compensation in the sum of £18,000.
Summary of Conclusions
204. For the reasons given in this judgment I have reached the following main conclusions
on the issues identified at [18] above:
(1) The personal data about the delivery of “illicit cash” to Mr Putin did amount to
sensitive personal data about alleged criminality.
(2) The Fusion Disclosure was made for purposes falling within the Legal Purposes
Exemption. The Fusion Disclosure was, for that reason, exempt from the Notice
Requirement contained in Schedule 1 Part II para 2; the application of that
requirement would be inconsistent with the disclosure. But the Fusion
Disclosure was not exempt from the Fourth Principle, or from s 14(1)-(3).
(3) The purpose of national security requires that the National Security Disclosures
be exempt from the Notice Requirement. But it does not require any further
exemption from the First or Fourth Principles.
(4) Neither the Fusion Disclosure nor the National Security Disclosures were in
breach of the First Principle. They all satisfied at least one condition in Schedule
2 and one in Schedule 3.
(5) The personal data of which complaint is made are all factual, and not matters of
opinion. The claimants have discharged the burden of proving that the data are
inaccurate or misleading as a matter of fact.
(6) No breach of the Fourth Principle has been established in relation to propositions
(a), (b), (c) or (e), because Orbis has proved that this was third party information
which it recorded accurately, and took reasonable steps to verify. But Orbis
failed to take reasonable steps to verify the allegation in proposition (d), that the
first and second claimant used Mr Govorun to deliver illicit cash to Mr Putin in
the 1990s. A breach of the Fourth Principle is made out in that respect.
(7) I am prepared to grant a limited order for rectification in respect of all the
inaccurate data, but I decline to grant any wider remedy under DPA s 14(1)-(3),
on the grounds that this is not necessary or appropriate. I decline, for similar
reasons, to make a declaration. But I award compensation to each of the first
and second claimants. I assess the appropriate sum as £18,000 each.
EXHIBIT H
The Washington Post
Opinions
Devin Nunes is investigating me.

Here’s the truth.
By Jonathan M. Winer February 8
Jonathan M. Winer, a Washington lawyer and consultant, is a former U.S. deputy assistant secretary of state for
international law enforcement and former special envoy for Libya.
House Intelligence Committee Chairman Devin Nunes (R-Calif.) announced last week that the next phase of his
investigation of the events that led to the appointment of special counsel Robert S. Mueller III will focus on the State
Department. His apparent area of interest is my relationship with former British intelligence professional
Christopher Steele and my role in material that Steele ultimately shared with the FBI.
Here’s the real story: In the 1990s, I was the senior official at the State Department responsible for combating
transnational organized crime. I became deeply concerned about Russian state operatives compromising and
corrupting foreign political figures and businessmen from other countries. Their modus operandi was sexual
entrapment and entrapment in too-good-to-be-true business deals.
After 1999, I left the State Department and developed a legal and consulting practice that often involved Russian
matters. In 2009, I met and became friends with Steele, after he retired from British government service focusing on
Russia. Steele was providing business intelligence on the same kinds of issues I worked on at the time.
In 2013, I returned to the State Department at the request of Secretary of State John F. Kerry, whom I had previously
served as Senate counsel. Over the years, Steele and I had discussed many matters relating to Russia. He asked me
whether the State Department would like copies of new information as he developed it. I contacted Victoria Nuland, a
career diplomat who was then assistant secretary of state for European and Eurasian affairs, and shared with her
several of Steele’s reports. She told me they were useful and asked me to continue to send them. Over the next two
years, I shared more than 100 of Steele’s reports with the Russia experts at the State Department, who continued to
find them useful. None of the reports related to U.S. politics or domestic U.S. matters, and the reports constituted a
very small portion of the data set reviewed by State Department experts trying to make sense of events in Russia.
5/15/2018
In the summer of 2016, Steele told me that he had learned of disturbing information regarding possible ties between
Donald Trump, his campaign and senior Russian officials. He did not provide details but made clear the information
involved “active measures,” a Soviet intelligence term for propaganda and related activities to influence events in
other countries.
In September 2016, Steele and I met in Washington and discussed the information now known as the “dossier.”
Steele’s sources suggested that the Kremlin not only had been behind the hacking of the Democratic National
Committee and the Hillary Clinton campaign but also had compromised Trump and developed ties with his
associates and campaign.
I was allowed to review, but not to keep, a copy of these reports to enable me to alert the State Department. I
prepared a two-page summary and shared it with Nuland, who indicated that, like me, she felt that the secretary of
state needed to be made aware of this material.
In late September, I spoke with an old friend, Sidney Blumenthal, whom I met 30 years ago when I was investigating
the Iran-contra affair for then-Sen. Kerry and Blumenthal was a reporter at The Post. At the time, Russian hacking
was at the front and center in the 2016 presidential campaign. The emails of Blumenthal, who had a long association
with Bill and Hillary Clinton, had been hacked in 2013 through a Russian server.
While talking about that hacking, Blumenthal and I discussed Steele’s reports. He showed me notes gathered by a
journalist I did not know, Cody Shearer, that alleged the Russians had compromising information on Trump of a
sexual and financial nature.
What struck me was how some of the material echoed Steele’s but appeared to involve different sources.
On my own, I shared a copy of these notes with Steele, to ask for his professional reaction. He told me it was
potentially “collateral” information. I asked him what that meant. He said that it was similar but separate from the
information he had gathered from his sources. I agreed to let him keep a copy of the Shearer notes.
Given that I had not worked with Shearer and knew that he was not a professional intelligence officer, I did not
mention or share his notes with anyone at the State Department. I did not expect them to be shared with anyone in
the U.S. government.
But I learned later that Steele did share them — with the FBI, after the FBI asked him to provide everything he had on
allegations relating to Trump, his campaign and Russian interference in U.S. elections.
I am in no position to judge the accuracy of the information generated by Steele or Shearer. But I was alarmed at
Russia’s role in the 2016 election, and so were U.S. intelligence and law enforcement officials. I believe all Americans
5/15/2018
should be alarmed — and united in the search for the truth about Russian interference in our democracy, and
whether Trump and his campaign had any part in it.
Read more on this topic:
Josh Rogin: Trump allies seek to tie Kerry’s State Department to the Steele dossier
David Ignatius: The truth about the FBI’s Russia probe
Greg Sargent and Paul Waldman: The Nunes memo is out. It’s a joke and a sham.
 3860 Comments
The story must be told.

Your subscription supports journalism that matters.
Try 1 month for $1
5/15/2018
EXHIBIT I
Glenn Simpson August 22, 2017

Washington, DC
Page 1
1 SENATE JUDICIARY COMMITTEE
2 U.S. SENATE
3 WASHINGTON, D.C.
7 INTERVIEW OF: GLENN SIMPSON
10
11 TUESDAY, AUGUST 22, 2017
12 WASHINGTON, D.C.
13
14
15
16
17 The interview in this matter was held at the
18 Hart Senate Office Building, commencing at 9:34 a.m.
19
20
21
22
23
24
25
Alderson Court Reporting

1-800-FOR-DEPO www.aldersonreporting.com

Washington, DC
Page 83
1 we gave Chris a sort of assignment that would be
2 typical for us which was pretty open ended. We
3 said see if you can find out what Donald Trump's
4 been doing on these trips to Russia. Since Chris
5 and I worked together over the years there's a lot
6 that didn't need to be said. That would include
7 who is he doing business with, which hotels does he
8 like to stay at, you know, did anyone ever offer
9 him anything, you know, the standard sort of things
10 you would look at. I don't think I gave him any
11 specific instructions beyond the general find out
12 what he was up to.
13 Q. And was anyone else -- did you engage
14 anyone else to do that particular research?
15 A. In Russia?
16 Q. Yes.
17 A. So we had other people like Ed Baumgartner
18 who, you know, by this time -- I guess Prevezon was
19 still winding down, but who would do Russian
20 language research which didn't involve going to
21 Russia. It just involves reading Russian newspaper
22 accounts and that sort of thing.
23 Q. So was Mr. Baumgartner also working on
24 opposition research for Candidate Trump?
25 A. At some point, I think probably after the


Washington, DC
Page 84
1 end of the Prevezon case we asked him to help with
2 I think -- my specific recollection is he worked on
3 specific issues involving Paul Manafort and
4 Ukraine.
5 Q. With regard to the presidential election
6 of 2016?
7 A. Yes.
8 Q. We had talked about work for multiple
9 clients. What steps were taken, if any, to make
10 sure that the work that Mr. Baumgartner was doing
11 for Prevezon was not shared across to the clients
12 you were working for with regard to the
13 presidential election?
14 A. He didn't deal with them. He didn't deal
15 with the clients. There wouldn't have been any
16 reason to -- he operates under the same rules that
17 I do.
18 Q. And with regard to Mr. Steele, did he ever
19 do any work for Fusion GPS on the Prevezon
20 litigation matter?
21 A. No.
22 Q. It's my understanding that Mr. Steele
23 works with a company called Orbis & Associates.
24 Did anyone else at Orbis, to the best of your
25 knowledge, work with Mr. Steele on the engagement


Washington, DC
Page 85
1 that you had with him related to Candidate Trump?
2 A. I mean, I don't know their names.
3 Q. So do you know whether anyone else worked
4 with him?
5 A. Yes. I mean, do you mean as
6 subcontractors or within his company?
7 Q. First within his company.
8 MR. LEVY: If you know.
9 BY THE WITNESS:
10 A. I mean, I just don't remember their names.
11 I remember meeting somebody in London who I think
12 worked on it, but I just don't remember.
13 Q. Somebody else associated with Orbis?
14 A. Yes.
15 Q. With regard to the assignment that you
16 gave to Mr. Steele to do Russia-related research
17 for Candidate Trump, is that an accurate way to
18 describe it? I said Russia-related research with
19 regard to Candidate Trump. Would that be a fair
20 way to describe the assignment?
21 A. Yes.
22 Q. Did you have any input into the actual
23 work that he did? Did you give him directions as
24 to what to research specifically?
25 A. I don't recall giving him specific


Washington, DC
Page 103
1 that they had provided to Fusion?
2 A. I'm sorry. Can you say that again.
3 Q. Did Baker Hostetler or Prevezon direct
4 Fusion to relay to the media information that they
5 had provided to you?
6 A. I don't specifically recall an example of
7 that, but I think as a general sort of operating
8 principle we were working at their direction and
9 they were providing us with, you know, case
10 information. So I think so, but I just don't have
11 an idea.
12 Q. And did anyone at Fusion or perhaps
13 Mr. Baumgartner review Russian documents related to
14 the Prevezon matter?
15 A. Yes.
16 Q. Do any --
17 A. Most of them were Russian court
18 documents.
19 Q. Do any Fusion employees or associates
20 speak Russian?
21 A. No. I'll qualify that. Depends on how
22 you define associate. Edward isn't an employee of
23 the company, but he speaks Russian. He's a
24 subcontractor.
25 Q. Aside from Mr. Baumgartner, do you have


Washington, DC
Page 189
1 MR. LEVY: The meetings?
2 MR. DAVIS: The dinner after the hearing.
3 BY THE WITNESS:
4 A. The purpose of the trip was the hearing.
5 It was routine for me to attend hearings. So I
6 would bill them -- my office would bill them for my
7 train trips and hotels depending on whether there
8 was -- whether it was specifically for the Prevezon
9 case. I don't know if -- I don't know for a fact
10 that we billed them.
11 Q. Did you travel with any other members of
12 the Prevezon team either to or from New York?
13 A. I don't think so.
14 Q. So I think you've already stated that Ed
15 Baumgartner worked on both projects, on the
16 Prevezon project and another Trump investigation.
17 To the best of your knowledge, does Mr. Baumgartner
18 know Rinat Akhmetshin?
19 A. I don't know. I'd just like to clarify,
20 you know, my recollection is that Ed worked -- the
21 Prevezon thing wound down and I don't think I
22 brought Ed on until it was either ending or had
23 already ended.
24 Q. Can you clarify the time frame for when it
25 was winding down?

EXHIBIT J
From: Lewis, Alan S.

Sent: Friday, May 8, 2020 5:52 PM
To: 'Eikhoff, Christy Hull'
Subject: Fridman et al v. Bean et al subpoenas to Steele and Orbis
Attachments: Plaintiffs Subpoena to Orbis Business Intelligence (Fridman v. Bean).pdf; Plaintiffs
Subpoena to Christopher Steele (Fridman v. Bean).pdf
Hi Christy,
I hope that you are well.
Attached are subpoenas to Mr. Steele and to Orbis, for documents and testimony, in the lawsuit
brought by my clients against Simpson et al pending in federal district court in D.C.
Will you accept service of these subpoenas? I’d appreciate your letting me know.
Best,
Alan
Alan S. Lewis, Esq.

Carter Ledyard & Milburn LLP
2 Wall Street | New York, NY 10005
Direct 212.238.8647 | Fax 212.732.3232
lewis@clm.com | www.clm.com
1
From: Eikhoff, Christy Hull <Christy.Eikhoff@alston.com>

Sent: Monday, May 18, 2020 4:57 PM
To: Lewis, Alan S.
Cc: Ramsay, Kristi; Barnaby, Kelley
Subject: RE: Fridman et al v. Bean et al subpoenas to Steele and Orbis
Alan,
We will not accept service of these third-party discovery requests for our client, a British national in the United Kingdom.
Proper service can be effectuated through the Hague Convention following procedures used to obtain discovery from
these same third parties in Gubarev v. v. BuzzFeed, No. 17-60426-CV, S.D. Fla., a case in which we understand you have
entered, supported plaintiffs and followed closely.
Christy Hull Eikhoff

Alston & Bird
404-881-4496 direct
404-550-4823 mobile
Legal Assistant: Scott Bobo (scott.bobo@alston.com)
1
EXHIBIT K
From: Eikhoff, Christy Hull <Christy.Eikhoff@alston.com>

Sent: Thursday, July 16, 2020 10:36 AM
To: Lewis, Alan S.; Ramsay, Kristi
Cc: Kim Sperduto (ksperduto@stglawdc.com); Walsh, John J.; Dunn, Matthew D.; Barnaby,
Kelley
Subject: RE: Compliance with Judge Epstein Order/ Christopher Burrows
We have sent confirmation of filing of the joint report.
Regarding the subpoenas, wwe will not accept service of these third-party discovery requests for Mr. Burrows, a British
national in the United Kingdom. Proper service can be effectuated through the Hague Convention following procedures
used to obtain discovery from these same third parties in Gubarev v. v. BuzzFeed, No. 17-60426-CV, S.D. Fla., a case in
which we understand you have entered, supported plaintiffs and followed closely.
Regards,
Christy Hull Eikhoff

Alston & Bird
404-881-4496 direct
404-550-4823 mobile
Legal Assistant: Scott Bobo (scott.bobo@alston.com)
From: Lewis, Alan S. <Lewis@clm.com>

Sent: Wednesday, July 15, 2020 11:59 AM
To: Eikhoff, Christy Hull <Christy.Eikhoff@alston.com>; Ramsay, Kristi <Kristi.Ramsay@alston.com>
Cc: Kim Sperduto (ksperduto@stglawdc.com) <ksperduto@stglawdc.com>; Walsh, John J. <walsh@clm.com>; Dunn,
Matthew D. <MDunn@clm.com>; Barnaby, Kelley <Kelley.Barnaby@alston.com>
Subject: RE: Compliance with Judge Epstein Order/ Christopher Burrows
EXTERNAL SENDER – Proceed with caution
Christy,
Please see the attached status report with Plaintiffs’ position inserted.
On another subject, would you accept service of subpoenas to Christopher Burrows for documents
and testimony in the lawsuit brought by my clients against Simpson et al pending in federal district
court in D.C. While I can anticipate your answer, based on my previous question about subpoenas to
Mr. Steele, it is nevertheless appropriate that I ask.
Alan
Alan S. Lewis, Esq.
1
2 Wall Street | New York, NY 10005
Direct 212.238.8647 | Fax 212.732.3232
lewis@clm.com | www.clm.com
2
EXHIBIT L
COMPANY INTELLIGENCE REPORT 2016/112
RUSSIA/US PRESIDENTIAL ELECTION: KREMLIN-ALPHA GROUP CO

OPERATION
Summary
- Top level Russian official confirms current closeness of Alpha Group·
PUTIN relationship. Significant favours continue to be done in both
directions and FRIDMAN and AVEN still giving informal advice to PUTIN,
especially on the US
- Key intermediary in PUTIN-Alpha relationship identified as Oleg
GOVORUN, currently Head ofa Presidential Administration department
but throughout the 1990s, the Alpha executive who delivered illicit cash
directly to PUTIN
- PUTIN personally unbothered about Alpha's current lack of investment in
Russia but under pressure from colleagues over this and able to exploit it
as lever over Alpha interlocutors
Detail
1. Speaking to a trusted compatriot In mid-September 2016, a top level

Russian government official commented on the history and current state
of relations between President PUTIN and the �lpha Group of businesses
led by oligarchs Mikhail FRIDMAN, Petr AVEN and German KHAN. The
Russian government figure reported that al�,9�gh they had had .their ups
and downs, the leading figures in Alpha cufre'ritly were on yery good
terms with PUTIN. Signltlcant favours continued to be done in both
directions, primarily political ones for PUTh{apcl buslne��/Jeg,1._�pe�Jor.
Alpha. Also, FRIDMAN and AVEN continued.tcfglve:tnformatadvlce to.
PUTIN on foreign policy, and especially aboufthe
· · ' · 1JS where he' distrusted
·· ·
advice being given to him by officials. ·· ·
2. Although FRIDMAN recently had m�t di.rectly ;lth•.PUTIN lnR1;1ssia, mti.ch

of the dialogue and business between them was mediated through a : ,
senior Presidential Administration official; 01.eij �9f
O�!J,N/�� r,
hea_ded the department therein re_sponslble. for �-e>ci�l Co-ope�ti. on:Wlth:.
c� re,��y .
the CIS. GOVORUN was trusted by PU!'IN �t(r�fen!]ypafi;�c§9p,�anie,f;L .:
him to Uzbekistan to pay respectsat he,fo�,§��etfi
� 1:T!fi�:t�!!4i#f ·/;,· :· ,.: .• ·,
KARIMOV. Ho�evera.ccprd�ng.tQ,tqe tQp!,Jev�l,::{{µ§slan go,�,rmnerit:'; ·. ,,'.':f·-'r.,;,,
m ;, ' ,' · :.� ..
.
o cjaI , durlng �.he) 990s·GOV0R.,Utfhad,b'eei(HeadfofGoven
's,,,7: ',,;,+�,_;��Cl,l�"+,
_:�,;i(��,d;.<:'''�
un9nf\i��'�?1::,::ifr:r ;,c;·; 7
-l(t;;"':"$..:./4,. :,,',<�,,
,
r_ ,>
\})
I'''�-�·- ,:
S
� ;,.: ,'
,
. Relations at Alpha Grouj{ana;1n:reait�y::f11�:tcTHt:f;f11fif&hiaQrcirrtJ�f ,,'�;:f� �;�/<,;/,�':,
. ':�]iit;�!;ttJt' . . . �:�tit11fti'l J,f;,dt�V"�/1i:J11c;{

· •_:s.i�C�(£(;Zj•{:t�Jl�1jL
used by FRIDMAN and AVEN to deliver large amounts of fllicit cash to the
Russian president, at that tlme deputy Mayor of St Petersburg. Given that
and the continuing sensitivity of the PUT(N-Alpha relationship, and need
for plausible deniabillty, much of the contact between them was now
Indirect and entrusted to the relatively low profile GOVORUN.
3. The top level Russian government official described the PUTIN-Alpha

relationship as both carrot and stick. Alpha held 'komprornat' on PUTIN
and his corrupt business activities from the 1990s whilst although not
personally overly bothered by Alpha's failure to reinvest the proceeds of
its TNK oil company sale lnto the Russian economy since, the Russian
president was able to use pressure on this count from senior Kremlin
colleagues as a lever on FRIDMAN and AVEN to make them do his
political bidding.
'
14 September 2016
EXHIBIT M
IN THE HIGH COURT OF JUSTICE Claim No. HQ17D00413

QUEEN’S BENCH DIVISION
BETWEEN:-
(1) ALEKSEJ GUBAREV

(3) WEBZILLA LIMITED
Claimants
-and-
(1) ORBIS BUSINESS INTELLIGENCE LIMITED

(2) CHRISTOPHER STEELE
Defendants
_____________________________________________________
DEFENDANTS’ CLOSING SUBMISSIONS

_____________________________________________________
TABLE OF CONTENTS
Description Paragraphs
A. Introduction 1 - 13
B. Liability for Publication of the December 14 - 91

Memorandum by BuzzFeed
The obscure and changing nature of the Claimants’ 14 - 18
case
What is the applicable legal test for determining 19- 32
whether the Defendants are liable as co-publishers in
respect of the BuzzFeed publication?
Application of the relevant legal test to the facts of this 33- 91
case
D. Qualified Privilege 92 - 104
Legal principles 92 - 95
Submissions on qualified privilege 96 - 104
E. Meaning of the Words Complained Of 105 - 116
The words complained of 105
1
“copies of the memoranda were not disclosed by Fusion to its clients”.

Both documents explain clearly that Fusion did not provide copies of
the pre-election memoranda to Perkins Coie.
The Defendants’ disclosure
76. Lastly, in an attempt to overcome the self-evident weakness of their case, the
Claimants have resorted to urging the Court to draw “adverse inferences”
regarding the Defendants’ evidence on the basis of the Defendants’ approach to
disclosure. However, there is no basis for drawing adverse inferences against
the Defendants on this basis.
77. First, as explained in Mr Mathieson’s witness statement {F/28/1}, the Defendants

have been the blameless victims of serious professional failures by the partner at
RPC who had responsibility for this matter until very recently. A summary of the
serious defects in her conduct of matters relating to disclosure is set out at §§15-
21 of the Defendants’ skeleton argument for the hearing on 30 March 2020, which
the Court is requested to read {F/30/5-9}. As Mr Mathieson summarises, “the
partner at RPC with responsibility for this case until mid-February 2020 actively,
seriously and repeatedly misled the Defendants about these proceedings”
{F/26/3}. That misconduct included (but was not limited to):
(1) withholding the Defendants’ disclosure for many months in breach of a court
order and without telling the Defendants;
(2) concealing the Claimants’ repeated complaints about the failure to provide
disclosure for many months;
(3) concealing the fact that the Claimants had applied for an order striking out
the Defendants’ defence if they did not provide their disclosure;
(4) failing to show the Defendants’ disclosure statement and list dated 29 July
2019 to the Defendants (and instead signing it herself and then serving it on
12 December 2019 without showing the Defendants)125;
125
See WS Mathieson at §24 {F/28/10}
52
(5) concealing the fact that in late December 2016 the court made an unless
order and an indemnity costs order against the Defendants;
(6) concealing the fact that the partner had served a witness statement in late
December 2019 which purported to explain why the earlier disclosure order
had been breached; and
(7) providing the Defendants with a falsified version of a court order in order to
conceal the true orders made by the court.
78. The Claimants’ criticisms of the Defendants’ disclosure must be assessed with
this important – indeed quite extraordinary – background firmly in mind.
79. Further, as Mr Mathieson describes in his statement126 – and as will have been
evident to the Court during Mr Steele’s cross-examination – Mr Steele was
shocked and dismayed when he was first informed in March 2020127 of the many
serious lapses committed by the former RPC partner. He remains extremely
upset and distressed by those serious lapses, for which he and Orbis bear no
responsibility whatsoever. Mr Steele’s evident dismay is entirely consistent with
him being an honest witness and litigant.
80. Secondly, specific criticism is made of the fact that the Defendants did not
disclose copies of communications between Mr Steele and Mr Bensinger until
earlier this year. Specific criticism is also made of a sentence in a letter from RPC
dated Friday 27 March 2020128, which failed to mention Mr Steele’s meeting with
Mr Bensinger in January 2017.
81. In respect of the 27 March letter:
(1) The focus of the letter was on disclosure of electronic documents. It was
sent on the last working day before a hearing of the Claimants’ application
126
See WS Mathieson at §15 {F/28/5}
127
Mr Mathieson informed the Defendants of the position in the week commencing 2
March 2020: see WS Mathieson at §17 {F/28/5}
128
The sentence in question reads: “Finally, other than the face to face meetings that
have been admitted, we are informed that Mr Steele did not conduct communications with
Schedule A/B individuals by any other method.” {F/33/50}
53
for specific disclosure of various categories of documents. The sentence in

question was made in direct response to the section of MWE’s letter dated
25 March headed “Communications by WhatsApp, Signal and Skype”129.
(2) It was in this context of documentary disclosure that the statement by RPC
regarding “method[s]” of communication was made. Mr Steele is unsure
whether he had even read the letter before it was sent.130 If he did, it is
perhaps unsurprising that he would not have noticed that a single sentence
in a three-page letter drafted by his solicitors concerning disclosure of
electronic documents was erroneous because it failed to reference the
existence of a particular face-to-face (i.e. non-documentary) conversation.
It is particularly understandable that Mr Steele would have failed to notice
that error in circumstances where he was still reeling from the discovery just
three weeks earlier of the extensive wrongdoing by the former RPC partner.
(3) When asked to revisit and consider the sentence during cross-examination,
Mr Steele candidly admitted that the sentence in question was an error.131
In any event, it was an error of no consequence (and certainly no detriment
to the Claimants) because:
(a) Two weeks after RPC’s letter was sent the communications with Mr
Bensinger were fully disclosed (as explained below); and
(b) Less two weeks after that, on 20 April 2020 Mr Steele served his
witness statement which provided a full and honest account of his
interactions with Mr Bensinger.
82. In relation to the messages between Mr Steele and Mr Bensinger, these were
fully disclosed on 10 April 2020 following a comprehensive set of further searches
and reviews under the supervision of solicitors and counsel who (unlike the former
RPC partner who oversaw the previous disclosure exercise) acted diligently in
accordance with their professional duties. This new disclosure process:
129
{F/33/46}
130
{Day4/110:13-15}
131
{Day4/117:21}
54
(1) was conducted under the careful supervision of a new and highly
experienced partner at RPC (Mr Mathieson) who had taken over conduct of
the case the previous month;
(2) involved both extensive manual and electronic searches of relevant

repositories of documents;
(3) involved the application of an expanded date range132 and a new set of 80
keyword search terms; and
(4) involved reviews of responsive documents by both the Defendants’ leading

and junior counsel (who each personally reviewed all of the messages
between Mr Steele and David Kramer and between Mr Steele and Mr
Bensinger for the purpose of identifying which messages fell within the
scope of the Defendants’ standard disclosure obligations133).
83. The full disclosure of the Bensinger messages following a rigorous properly
managed disclosure review – in which the Defendants fully participated – is
inconsistent with any attempt to “suppress” that evidence.
84. Mr Steele has clearly explained that he did not discuss the pre-election
memoranda or the December memorandum with Mr Bensinger, nor did he
authorise or intend Mr Kramer to do so. There is no proper basis to doubt the
truthfulness of that evidence. It therefore follows that Mr Steele had no motive for
concealing either his meeting or his communications with Mr Bensinger.
85. Third, it is not uncommon for parties to make innocent errors with disclosure.
Indeed, this is reflected by the Claimants’ own disclosure in these proceedings,
which has been supplemented on a number of occasions after disclosable
documents were inadvertently not disclosed. To give one particularly recent
132
Under the original disclosure order the date range for the Defendants’ disclosure
searches ended with the date of BuzzFeed’s publication (10 January 2017) (see {F/25/1-5}).
In March 2020, the Defendants agreed to a consent order which expanded the end of that
date range to April 2017 in relation to communications with Mr Kramer and Mr Bensinger (see
§2(2) of the consent order at {B/14/2}
133
The terms of the consent order were expressly agreed on the basis that the
Defendants’ counsel would undertake such a review.
55
example, as a result of an “oversight”134 (by the Claimants or their solicitors – it is

not clear which) the Third Claimant’s financial statements for 2018 – an obviously
important set of document in the context of the serious financial loss issue – were
not disclosed until mid-way through Mr Gubarev’s cross-examination on the
second day of the trial. The Defendants have not sought to invite any adverse
inference to be drawn from the late and unexplained disclosure of this document.
This is because unintentional errors in disclosure (even careless ones) do not
provide a proper basis for drawing adverse inferences.
86. Fourth, the Claimants’ criticisms of the Defendants’ disclosure cannot be

considered in isolation from the Claimants’ approach to their own disclosure.
Indeed, there is an element of hypocrisy to a number of the Claimants’ criticisms.
For example, Mr Steele is criticised for what is said to be the “peculiar” fact that
certain messages were disclosed in the form of “screenshots from his [Mr
Steele’s] mobile phone”.135 Yet the Claimants have done exactly the same thing.
The messages which are referred to and quoted at paragraph 11.5(b) of the
RRRAPOC {A/12/5} were disclosed in the form of screenshots from a mobile
phone and computer; the native electronic versions were never provided to the
Defendants. In cross-examination, Mr Dvas expressly confirmed that, “My
understanding was it was okay to give them to our lawyers in that form”136 and
admitted that he had failed to disclose other communications with the individual
in question that took place between the dates of the disclosed communications.137
87. Again, the Defendants did not – and indeed could not – suggest that the
disclosure of screenshots (apparently on the instructions of the Claimants’
solicitors) and the omission to disclose intervening messages in Mr Dvas’ chain
of communications was a dishonest attempt to suppress disclosable evidence.
88. Finally, the suggestion that any litigant has deliberately suppressed documents
and then given a dishonest account to the Court about this is a very serious
allegation. It is a particularly serious allegation to level against a former senior
134
See email from Lynsey McIntyre to RPC at 08:01 on 21 July 2020
135
Claimants’ Opening Submissions §99 {A/27/22}
136
{Day3/25:19} - {Day3/26:1}
137
{Day3/22:13-16}
56
Crown servant of good character and with a distinguished record of responsible

public service.
89. It is trite law that serious allegations require cogent evidence in order to be
established. As Andrew Smith J explained in Fiona Trust v Privalov [2010] EWHC
3199 (Comm) at [1438]:
“It is well established that "cogent evidence is required to

justify a finding of fraud or other discreditable conduct": per
Moore-Bick LJ in Jafari-Fini v Skillglass Ltd., [2007] EWCA Civ
261 at para.73. This principle reflects the court's conventional
perception that it is generally not likely that people will
engage in such conduct: "where a claimant seeks to prove a
case of dishonesty, its inherent improbability means that,
even on the civil burden of proof, the evidence needed to
prove it must be all the stronger", per Rix LJ in Markel v
Higgins, [2009] EWCA 790 at para 50. The question remains one
of the balance of probability, although typically, as Ungoed-
Thomas J put it in In re Dellow's Will Trusts, [1964] 1 WLR 415 ,
455 (cited by Lord Nicholls in In re H, [1996] AC 563 at p.586H),
"The more serious the allegation the more cogent the
evidence required to overcome the unlikelihood of what is
alleged and thus to prove it". Associated with the
seriousness of the allegation is the seriousness of the
consequences, or potential consequences, of the proof of the
allegation because of the improbability that a person will risk
such consequences: see R(N) v Mental Health Review Tribunal
(Northern Region), [2005] EWCA 1605 para 62, cited in Re
Doherty, [2008] UKHL 33 para 27 per Lord Carswell.” (Emphasis
added) 138
90. Applying those well-established principles here, the evidence comes nowhere
close to providing a basis for the Court to conclude that Mr Steele has made any
attempt to suppress disclosable documents or to provide untruthful evidence to
the Court on any matter. There is therefore no basis for drawing any adverse
inference against the Defendants.
138
For a recent example of the application of this principle, see the judgment of the High
Court in Ras Al Khaimah Investment Authority v Azima [2020] EWHC 1327 (Ch) at [375] et
seq.
57
EXHIBIT N
7/28/2020 Case 1:17-cv-02041-RJL Document
The F.B.I. Pledged to Keep a 90-2Trump
Source Anonymous. Filed
Allies08/04/20 Page -189
Aided His Unmasking. of 191
The New York Times
https://nyti.ms/2WU7EjD
The F.B.I. Pledged to Keep a Source Anonymous. Trump Allies Aided His Unmasking.
After a Russia expert who had collected research on Donald Trump for a disputed dossier agreed to tell the F.B.I. what he knew about it, law
enforcement officials declassified a road map to identifying him.
By Adam Goldman and Charlie Savage
July 25, 2020
WASHINGTON — Not long after the early 2017 publication of a notorious dossier about President Trump jolted Washington, an expert in
Russian politics told the F.B.I. he had been one of its key sources, drawing on his contacts to deliver information that would make up some
of the most salacious and unproven assertions in the document.
The F.B.I. had approached the expert, a man named Igor Danchenko, as it vetted the dossier’s claims. He agreed to tell investigators what
he knew with an important condition, people familiar with the matter said — that the F.B.I. keep his identity secret so he could protect
himself, his sources and his family and friends in Russia.
But his hope of remaining anonymous evaporated last week after Attorney General William P. Barr directed the F.B.I. to declassify a
redacted report about its three-day interview of Mr. Danchenko in 2017 and hand it over to Senator Lindsey Graham, Republican of South
Carolina and chairman of the Senate Judiciary Committee. Mr. Graham promptly made the interview summary public while calling the
entire Russia investigation “corrupt.”
The report blacked out Mr. Danchenko’s name and other identifying information. But within two days, a post on a newly created blog
entitled “I Found the Primary Subsource” identified him, citing clues left visible in the F.B.I. document. A pseudonymous Twitter account
created in May then promoted the existence of the blog. And the next day, RT, the Kremlin-owned, English-language news and propaganda
outlet, published an article amplifying Mr. Danchenko’s identification.
The decision by Justice Department and F.B.I. leaders to divulge such a report was highly unusual and created the risk it would help
identify a person who had confidentially provided information to agents, even if officials did not intend to provide such a road map. The
move comes at a time when Mr. Barr, who is to testify before lawmakers on Tuesday, has repeatedly been accused of abusing his powers to
help Mr. Trump politically.
Former law enforcement officials said the outing will make it harder for F.B.I. agents to gain the trust of people they need to cooperate in
future and unrelated investigations.
“These things have to remain very closely held because you put witnesses at risk,” said James W. McJunkin, a former F.B.I. assistant
director for counterterrorism. “To release sensitive information unnecessarily that could jeopardize someone’s life is egregious.”
A lawyer for Mr. Danchenko, Mark E. Schamel, said that because his client’s name had already been exposed, he would not ask The New
York Times to withhold it. He acknowledged that “Igor Danchenko has been identified as one of the sources who provided data and
analysis” to Christopher Steele, the British former spy who compiled the dossier and whose last name has become shorthand for it.
Mr. Danchenko’s identity is noteworthy because it further calls into question the credibility of the dossier. By turning to Mr. Danchenko as
his primary source to gather possible dirt on Mr. Trump involving Russia, Mr. Steele was relying not on someone with a history of working
with Russian intelligence operatives or bringing to light their covert activities but instead a researcher focused on analyzing business and
political risks in Russia.
Spokespeople at both the F.B.I. and the Justice Department declined to comment. An email sent to an address listed on the blog was not
returned.
Mr. Trump’s supporters on Capitol Hill have long sought access to Justice Department and F.B.I. documents about the Russia
investigation. The F.B.I. director, Christopher A. Wray, told lawmakers in late 2017 that the bureau was wary of turning over records
related to its effort to verify the Steele dossier to Congress. “We are dealing with very, very dicey questions of sources and methods, which
is the lifeblood of foreign intelligence and our liaison relationships with our foreign partners,” he said.
But since his confirmation early last year, Mr. Barr and other Trump appointees have approved a wave of extraordinary declassifications
that the president’s allies, including Mr. Graham, have used to attack the Russia inquiry.
https://www.nytimes.com/2020/07/25/us/politics/igor-danchenko-steele-dossier.html? 1/3
The New York Times
Mr. Graham said he had asked the F.B.I. to declassify the interview report after it was described in an inspector general report last year
because he wanted the public to read it. He stressed that he did not know the identity of Mr. Steele’s source and said he did not know
whether the F.B.I. released identifying information it should have protected, saying the bureau had appeared to be “painstaking” in
redacting such details.
“I don’t know how he was exposed,” Mr. Graham said in an interview on Friday. “I didn’t see anything in the memo exposing who he was. I
mean, you can believe these websites if you want to — I don’t know. I know this: It’s important for the country to understand what
happened here.”
In addition to their political implications, the documents have at times revealed the closely held secrets that Mr. Wray feared jeopardizing:
sources of information and the methods used for gathering it.
The F.B.I.’s headquarters in Washington. The disclosures will make it harder for F.B.I.
agents to gain the trust of potential sources, former law enforcement officials said. Anna
Moneymaker/The New York Times
Transcripts of recordings released in April resulted in the identification of a confidential F.B.I. informant who had agree to wear a wire
when talking to George Papadopoulos, a former Trump adviser who was convicted of lying to the F.B.I. Other released transcripts of a
Russian diplomat’s conversations with former national security adviser Michael T. Flynn revealed that the bureau was able to monitor the
phone line of the Russian Embassy in Washington even before a call connected with Mr. Flynn’s voice mail.
The unmaskings from the release of the F.B.I. report have already spiraled beyond Mr. Danchenko. Building on the knowledge of his
identity, another Twitter user named a likely source for Mr. Danchenko. Online sleuths were trying to identify others from his network who
were cited but not named in the Steele dossier.
The release of Mr. Danchenko’s interview summary likely put him and other sources in Russia’s sights, said Senator Mark Warner of
Virginia, the top Democrat on the Senate Intelligence Committee.
“Under Attorney General Barr, the levers of the Department of Justice continue to be weaponized in defense of the president’s political
agenda, even at the expense of national security,” said Mr. Warner, who did not confirm that Mr. Danchenko was Mr. Steele’s primary
source or discuss his committee’s own investigation into Russian election interference. “I’m deeply concerned by this release. There is no
doubt that the Russians are poring over it to see if they can identify this individual or other sources.”
Mr. Danchenko also cooperated with the intelligence committee on condition of confidentiality, according to two people familiar with its
investigation.
Some posts on the blog that revealed Mr. Danchenko’s name are dated before Mr. Graham released the interview report, but the Twitter
user who promoted the blog said he or she had backdated the posts to change their order.
Born in Ukraine, Mr. Danchenko, 42, is a Russian-trained lawyer who earned degrees at the University of Louisville and Georgetown
University, according to LinkedIn. He was a senior research analyst from 2005 to 2010 at the Brookings Institution, where he co-wrote a
research paper showing that, as a student, President Vladimir V. Putin of Russia appeared to have plagiarized part of his dissertation.
According to his interview with the F.B.I., Mr. Steele contacted Mr. Danchenko around March 2016 and assigned him to ask people he knew
in Russia and Ukraine about connections, including any ties to corruption, between a pro-Russian government in Ukraine and the veteran
Republican strategist Paul Manafort. Mr. Steele did not explain why, but Mr. Manafort joined the Trump campaign around that time and
The New York Times
was later promoted to its chairman. He was convicted in 2018 of tax and bank fraud and other charges that grew out of the Russia
investigation.
Mr. Steele later expanded Mr. Danchenko’s assignment to look for any compromising information about Mr. Trump.
By Jan. 13, 2017, the F.B.I. had identified Mr. Danchenko, who soon agreed to answer investigators’ questions in exchange for immunity.
The F.B.I. told a court it found Mr. Danchenko “truthful and cooperative,” according to the report by the Justice Department inspector
general, Michael E. Horowitz, although a supervisory F.B.I. intelligence analyst said Mr. Danchenko may have minimized aspects of what
he told Mr. Steele.
Mr. Graham said he wanted the public to be able to see for itself how the interview report “clearly shows that the dossier was not reliable
and they continued to use it anyway.”
Mr. Danchenko did nothing wrong in accepting a paid assignment to gather allegations about Mr. Trump’s ties to Russia and conveying
them to Mr. Steele’s research firm, Orbis Business Intelligence, said Mr. Schamel, who attended his client’s F.B.I. debriefings but whose
name was redacted from the report about them.
“Mr. Danchenko is a highly respected senior research analyst; he is neither an author nor editor for any of the final reports produced by
Orbis,” Mr. Schamel said. “Mr. Danchenko stands by his data analysis and research and will leave it to others to evaluate and interpret any
broader story with regard to Orbis’s final report.”
The Steele dossier was deeply flawed. For example, it included a claim that Mr. Trump’s former lawyer Michael D. Cohen had met with a
Russian intelligence officer in Prague to discuss collusion with the campaign. The report by the special counsel who took over the Russia
investigation, Robert S. Mueller III, found that Mr. Cohen never traveled to Prague.
And Mr. Danchenko’s statements to the F.B.I. contradicted parts of the dossier, suggesting that Mr. Steele may have exaggerated the
soundness of other allegations, making what Mr. Danchenko portrayed as rumor and speculation sound more solid.
The Steele dossier played no role in the F.B.I.’s opening of the Russia investigation in July 2016, and Mr. Mueller did not rely on it for his
report.
But its flaws have taken on outsized political significance, as Mr. Trump’s allies have sought to conflate it with the larger effort to
understand Russia’s covert efforts to tilt the 2016 election in his favor and whether any Trump campaign associates conspired in that
effort. Mr. Mueller laid out extensive details about Russia’s covert operation and contacts with Trump campaign associates, but found
insufficient evidence to bring any conspiracy charges.
The dossier did play an important role in a narrow part of the F.B.I.’s early Russia investigation: the wiretapping of Carter Page, a former
Trump campaign adviser with close ties to Russian officials, which began in October 2016 and was extended three times in 2017. The
Justice Department’s applications for court orders authorizing the wiretap relied in part on information from the dossier in making the
case that investigators had reason to believe that Mr. Page might be working with Russians.
Mr. Page was never charged, and Mr. Mueller’s report only briefly discussed him. Mr. Horowitz scathingly portrayed the wiretap
applications as riddled with errors and omissions.
Mr. Danchenko provided information to Mr. Steele that figured into one of the biggest flaws with those applications. Mr. Horowitz first
brought to public light that when the F.B.I. interviewed Mr. Steele’s primary source — who turned out to be Mr. Danchenko — his account
was inconsistent with important aspects of the dossier.
But law enforcement officials recycled the same language derived from the dossier in their final two applications for court orders to
continue wiretapping Mr. Page. They also told a court they had spoken to Mr. Steele’s primary source but without revealing that his
statements raised questions about the dossier’s credibility, which Mr. Horowitz said was misleading.
After the inspector general report, the F.B.I. conceded to the court that it should not have sought the last two renewals.
The disclosure of Mr. Danchenko’s identity — which the inspector general report concealed — also brought into focus another questionable
statement in the wiretap applications. Mr. Horowitz wrote that the last two applications described Mr. Steele’s source as “Russian-based.”
Though Mr. Danchenko visited Moscow while gathering information for Mr. Steele, he lives in the United States.
A criminal prosecutor appointed by Mr. Barr to scrutinize the Russia investigation, John H. Durham, the U.S. attorney in Connecticut, has
also focused on the dossier and asked questions about Mr. Danchenko, according to people familiar with aspects of his inquiry. Mr.
Schamel said he had not been contacted by Mr. Durham or his investigators.
Nicholas Fandos contributed reporting.

------------------------------------------------------------- X
GERMAN KHAN, :
:
Plaintiffs, :
:
Case No. 1:17-cv-02041 (RJL)
v. :
:
SIMPSON, :
:
Defendants. :
------------------------------------------------------------- X
PROPOSED ORDER
Upon consideration of Plaintiffs’ Motion for Issuance of Letters of Request for
International Judicial Assistance (the “Motion”), the Court ORDERS that:
The Motion is GRANTED; and
The Clerk is directed to issue the attached Letters of Request to the Queen’s Bench
Division, High Court of Justice, Royal Courts of Justice, Strand, London WC2A 2LL, United
Kingdom.
_____________________________
Richard J. Leon
Senior United States District Judge

------------------------------------------------------------- X
GERMAN KHAN, :
:
Plaintiffs, :
:
Case No. 1:17-cv-02041 (RJL)
v. :
:
SIMPSON, :
:
Defendants. :
------------------------------------------------------------- X
LETTER OF REQUEST FOR INTERNATIONAL JUDICIAL ASSISTANCE
PURSUANT TO THE HAGUE CONVENTION OF 18 MARCH 1970 ON THE TAKING
OF EVIDENCE ABROAD IN CIVIL OR COMMERCIAL MATTERS
The United States District Court for the District of Columbia (the “District Court” or the
“Court”) presents its compliments to the Senior Master of the High Court (Queen’s Bench
Division) of England and Wales, and requests assistance in obtaining evidence to be used in a
civil proceeding before this Court in the above-captioned proceedings (the “Action”).
This request is made pursuant to, and in conformity with The Hague Convention of 18
March 1970 on the Taking of Evidence Abroad in Civil or Commercial Matters (the “Hague
Convention”), to which both the United States and the United Kingdom are a party; the Evidence
(Proceedings in Other Jurisdictions) Act 1975, the Rules of the United States District Court for
the District of Columbia; and the Federal Rules of Civil Procedure.
The purpose of this Letter of Request (the “Request”) is to obtain oral testimony and
documentary evidence for use at trial from three non-party witnesses who all reside within your
jurisdiction: Mr. Christopher Steele, Mr. Edward Baumgartner, and Sir Andrew Wood, and (oral
testimony only) Mr. Christopher Burrows. The Request also seeks the production of
9603403.14
documentary evidence from Orbis Business Intelligence Ltd. (“Orbis”), being a company co-
founded by Mr. Steele and Mr. Burrows.
The District Court considers that the evidence sought is directly relevant to the issues in
dispute and is not discovery within the meaning of Article 23 of The Hague Convention; that is,
it is discovery intended to lead to relevant evidence for trial. It is expected, based on existing
timetables, that the District Court will schedule a trial to commence in or about late 2021.
It has been demonstrated to this Court that justice cannot be done amongst the parties to
the Action without the testimony and documentary evidence of the abovenamed witnesses. In
conformity with Article 3 of the Hague Convention, this Court respectfully submits the following
Request.
The District Court requests the assistance of an appropriate English judicial officer to
compel the appearance of the witnesses to give oral sworn testimony and to produce documents
on the subject matters for the date ranges as described in this Request.
It is requested that the appropriate judicial officer of England and Wales issue such orders
as are necessary to implement this Request for the witnesses to produce documents and to appear
before an examiner or other appropriate judicial authority in England and Wales to take their oral
sworn testimony at deposition in conformity with the procedures of the U.S. Federal Rules of
Civil Procedure or such other procedures as are acceptable.
The testimonies and document production sought are material to the issue pending in the
Action. Plaintiffs have approached the witnesses (or their known counsel or representative) as
follows in order to ascertain whether they would be willing to provide their voluntary assistance
in the Action in the United States.
9603403.14
a) Mr. Steele, Mr. Burrows, and Orbis. Plaintiffs communicated with known United
States counsel for Mr. Steele, Mr. Burrows, and Orbis, in order to ascertain whether
they would be willing to accept service of subpoenas on their behalf in the United
States to provide oral testimony and/or produce documents. Counsel indicated that
they are unwilling to accept service of subpoenas on their behalf in the United States.
b) Mr. Baumgartner. Plaintiffs are not aware of any counsel or representative for Mr.
Baumgartner in the United States. U.K. counsel for Plaintiffs wrote to Mr.
Baumgartner directly at his Edward Austin business address (copied to the business
email address) and asked whether Mr. Baumgartner would voluntarily produce
documentary evidence and appear for an examination. Plaintiffs will update the Court
as to any response received from Mr. Baumgartner.
c) Sir Andrew Wood. Plaintiffs are not aware of any counsel or representative for Sir
Andrew Wood in the United States. U.K. counsel for Plaintiffs wrote to Sir Andrew
directly at his Chatham House business address (copied to the gmail email address
given on Sir Andrew’s Chatham House online biography) and asked if Sir Andrew
would voluntarily produce documentary evidence and appear for an examination.
Plaintiffs will update the Court as to any response received from Sir Andrew Wood.
The District Court is authorized by Title 28, United States Code, sections 1781 and 1782
to extend similar assistance on request of the judicial authorities of England and Wales.
The District Court, through the offices of the representatives of Plaintiffs, is prepared to
reimburse the High Court of England and Wales and/or office for all costs incurred in executing
the instant Request and the assurance of its highest consideration.
The particulars of this Request pursuant to the Hague Convention are as follows:
9603403.14
1. Sender: Honorable Richard J. Leon

United States District Court for the District of Columbia
333 Constitution Avenue N.W.
2. Central Authority of COMPETENT AUTHORITY FOR

the Requested State: ENGLAND AND WALES
Senior Master
Queen’s Bench Division
High Court of Justice
Royal Courts of Justice
Strand
London WC2A 2LL
UNITED KINGDOM
3. Person to whom the Plaintiff’s Legal Representative in the U.K.:

executed request is to
be returned: Bernard O’Sullivan
Louise Boswell
CMS Cameron McKenna Nabarro Olswang LLP
Cannon Place
78 Cannon Street
London EC4N 6AF
United Kingdom
T +44 20 7067 3594
F +44 20 7367 2000
E bernard.o'sullivan@cms-cmno.com
louise.boswell@cms-cmno.com
On behalf of:
Honorable Richard J. Leon

Washington D.C. 20001
In conformity with Article 3 of the Convention, the undersigned applicant

has the honor to submit the following requests:
4a. Requesting Honorable Richard J. Leon

Judicial Authority: Senior United States District Judge
9603403.14
Washington D.C. 20001
4b. To the competent THE UNITED KINGDOM OF GREAT

authority of: BRITAIN AND NORTHERN IRELAND
4.c. Names of the case and Fridman v. Bean LLC, Case No. 1:17-CV-02041 (RJL),
any identifying number United States District Court for the District of Columbia
5. Names and addresses of

the parties and their
representatives:
a. Plaintiffs: Mikhail Fridman, Petr Aven, and German Khan
Represented in the U.S. by:

Alan S. Lewis
John J. Walsh
2 Wall Street
New York, NY 10005
Tel: +1 (212) 732-3200
-AND-
Kim H. Sperduto
Sperduto Thompson & Gassler PLC
Tel: +1(202) 408-8900
Represented in the U.K. by:

Bernard O’Sullivan
Louise Boswell
CMS Cameron McKenna Nabarro Olswang LLP
Cannon Place
78 Cannon Street
London EC4N 6AF
United Kingdom
T +44 20 7067 3594
F +44 20 7367 2000
E bernard.o'sullivan@cms-cmno.com
Louise.boswell@cms-cmno.com
b. Defendants: Bean LLC (a/k/a Fusion GPS) and Glenn Simpson
Represented in the U.S. by:
9603403.14
Joshua A. Levy
Rachel Clattenburg
Levy Firestone Muse LLP
Tel: +1(202) 845-3215
c. Other parties. The Christopher Steele

following non-parties, c/o Orbis Business Intelligence Ltd.,
which are the subject of 9-11 Grosvenor
this application are as Gardens, London SW1W 0BD
follows:
Represented in the U.S. 1 by:
Christina Hull Eikhoff
Kristin Ramsay
Alston & Bird LLP
1201 West Peachtree Street
Atlanta, GA 30309-3424
Tel: +1 (404) 881-7000
-AND-
Kelley C. Barnaby
Alston & Bird LLP
950 F Street, NW
Tel: +1 (202) 239-3687
Represented in the U.K. 2 by:

Reynolds Porter Chamberlain LLP
Tower Bridge House
St. Katharine’s Way
London E1W 1AA
United Kingdom
T: +44 20 3060 6000
1
The counsel identified for Mr. Steele and Orbis represents them in connection with the proceeding captioned Khan
v. Orbis Business Intelligence Ltd., Case No. 18-CV-0919. That case was originally brought in the Superior Court
of the District of Columbia, which dismissed it based on a local statute known as the D.C. Anti-SLAPP Act. Its
current posture involves the drafting of a petition by Plaintiffs to the United States Supreme Court. Mr. Steele and
Orbis are not parties to the Action in connection with which this Request is made.
2
The counsel identified for Mr. Steele and Orbis represents Orbis in connection with the Action captioned Aven and
others v. Orbis Business Intelligence Ltd., Claim No. HQ18M01646 / QB-2018-006349, in the High Court of
Justice, Queen’s Bench Division, Media & Communications List (the “U.K. Proceeding”), in which the High Court
recently rendered a judgment in favor of Plaintiffs on July 8, 2020. See Judgment, [2020] EWHC 1812 (QB),
available at https://www.bailii.org/ew/cases/EWHC/QB/2020/1812.html. Mr. Steele and Orbis are not parties to the
Action in connection with which this Request is made.
6
9603403.14
Orbis Business Intelligence Ltd.

9-11 Grosvenor
Gardens, London SW1W 0BD
See counsel identified on behalf of Christopher Steele
Christopher Burrows
c/o Orbis Business Intelligence Ltd.,
9-11 Grosvenor
Gardens, London SW1W 0BD
See counsel identified on behalf of Christopher Steele
and Orbis
Edward Baumgartner
c/o Edward Austin Limited
4 Old Park Lane
London W1K 1QW
United Kingdom
info@edward-austin.com
Counsel/representative unknown
Sir Andrew Wood

c/o The Royal Institute of International Affairs
Chatham House
10 St James's Square
London SW1Y 4LE
United Kingdom
andrewood40@gmail.com
Counsel/representative unknown
6. Nature and purpose of the proceedings and summary of the facts:
This civil Action concerns claims of defamation brought by Plaintiffs. The statements
alleged to be defamatory are in a two-page document (sometimes referred to as a “memorandum
or a “report”) that was prepared by Christopher Steele and Orbis Business Intelligence Ltd.
(“Orbis”) 3 and bears the label “Company Intelligence Report 2016” (“CIR 112”). Plaintiffs
allege that Mr. Steele and Orbis prepared CIR 112 at the behest of Defendants Bean LLC (a/k/a
3
References to “Orbis” in this Request shall include Orbis’s directors, principles, employees, contractors, agents,
and representatives.
7
9603403.14
Fusion GPS) (“Fusion”) 4 and Glenn Simpson (together, with Fusion, the “Defendants”) and that
Defendants thereafter published CIR 112, including its defamatory content, to members of the
media and others. As alleged by Plaintiffs, the challenged statements are defamatory because
they falsely accuse Plaintiffs of bribery and corruption, specifically related to Vladimir Putin,
and suggest that Plaintiffs cooperated with a Kremlin-orchestrated illegal campaign to interfere
with the 2016 U.S. presidential election.
Plaintiffs seek a judgment against Defendants finding that statements about Plaintiffs in
CIR 112 are false and defamatory and that Defendants published them. Plaintiffs seek
compensatory and/or punitive damages in amounts to be proven at trial, together with interest
and costs and fees.
Defendants deny any liability to Plaintiffs and have asserted several defenses, including
that the statements about Plaintiffs are not materially false; the publication of the statements was
privileged or otherwise protected by, inter alia, the First Amendment of the U.S. Constitution,
the neutral report privilege, and/or the Fair Report Privilege (under New York Civil Rights Law
Section 74); and Plaintiffs should be treated as “public figures” (either general purpose public or
limited purpose)—a category which subjects Plaintiffs to a burden to show that the defamatory
statements were published with “actual malice”, i.e., published with the knowledge that the
statements were false or with reckless disregard to whether they were true or false.
Plaintiffs have represented that they do not seek disclosure of communications or
documents that are protected from disclosure by the attorney client privilege, work product
doctrine, or other applicable privilege, nor do they seek to circumvent any privilege assertions,
4
References to “Fusion” in this Request shall include Fusion’s directors, principles, employees, contractors, agents,
and representatives.
8
9603403.14
however Plaintiffs do not waive the right to object to or challenge the propriety or validity of
claims that documents are privileged and the basis of such privilege claims.
Although Orbis produced to Plaintiffs some documents of Orbis and Mr. Steele in the
U.K. Proceeding, no documents relating to the creation or publication of CIR 112 were produced
and Plaintiffs have a good faith belief, bolstered by recent admitted failures of disclosure by Mr.
Steele in a similar matter involving Mr. Steele in the U.K., 5 that relevant documents exist and/or
that Orbis and/or Mr. Steele neglected to produce them. In addition, due to (i) Mr. Steele's recent
challenge to the U.S. Department of Justice seeking copies of certain of documents from the
U.K. Proceeding that would normally be available under applicable English law 6 and (ii) the
restrictions on the use of certain other documents produced in the U.K. Proceeding pursuant to
Rule 31.22 of the English Civil Procedure Rules, Plaintiffs seek a separate order from the High
Court permitting disclosure of evidence for use in this U.S. proceeding.
STAGE OF THE PROCEEDINGS
This Action was commenced by the filing of a Complaint by the Plaintiffs on October 3,
2017. The parties exchanged written discovery requests in October 2019. Written responses to
the requests were exchanged in November 2019 and supplemented in May 2020. Depositions
have not yet taken place. Fact discovery is scheduled to be concluded by January 12, 2021. A
trial is expected in or about late 2021.
THE WITNESSES AND ENTITIES FROM WHICH EVIDENCE IS SOUGHT
5
In the proceedings captioned Aleksej Gubarev and another v (i) Orbis Business Intelligence Limited and (ii)
Christopher Steele, Claim No. HQ17D00413, in the High Court of Justice, Queen’s Bench Division, the trial of
which recently took place between 20-24 July 2020 (“Gubarev U.K. Proceeding”). See Declaration of Alan Lewis
in support of the Motion, Exhibit (“Motion Ex.”) M, Defendants’ Closing Submissions in Gubarev U.K. Proceeding
(which were made public during the trial) at 52-57.
6
In the matter of an application by the United States of America (the United States Department of Justice) made in
the U.K. Proceeding.
9
9603403.14
Christopher Steele, 7 c/o Orbis Business Intelligence Ltd., located at 9-11 Grosvenor
Gardens, London SW1W 0BD.
Orbis Business Intelligence Ltd., located at 9-11 Grosvenor Gardens, London SW1W
0BD.
Christopher Burrows, 8 c/o Orbis Business Intelligence Ltd., located at 9-11 Grosvenor
Gardens, London SW1W 0BD.
Edward Baumgartner, 9 c/o Edward Austin Limited, located at 4 Old Park Lane,
London W1K 1QW.
Sir Andrew Wood,10 c/o The Royal Institute of International Affairs, Chatham House,
10 St James's Square, London SW1Y 4LE.
THE RELEVANCE OF EVIDENCE IS SOUGHT
Mr. Steele is the co-founder and director of Orbis and compiled the information in CIR
112, including the defamatory statements about Plaintiffs at issue in this Action, and disclosed or
provided CIR 112 (and the other reports that have collectively become known as the “Dossier”)
to others. As set forth in Plaintiffs’ Motion In Support of Request for International Judicial
Assistance (“Motion”), Defendants have formally identified Mr. Steele as an individual likely to
have information relevant to this Action and Defendants’ claims and defenses, such as
information relating to “CIR 112, including recipients of CIR 112, research related to matters in
CIR 112, events related to topics in CIR 112, and delivery of CIR 112.” 11
7
Mr. Steele is a director and joint founder of Orbis. See https://orbisbi.com/about-orbis/.
8
Mr. Burrows is a director and joint founder of Orbis. See https://orbisbi.com/about-orbis/.
9
Mr. Baumgartner is a founder and managing director of Edward Austin Limited ("Edward Austin"). See
https://www.edward-austin.com/about/team/.
10
Sir Andrew Wood is an Associate Fellow in the Russia and Eurasia Programme at Chatham House. See
https://www.chathamhouse.org/expert/sir-andrew-wood
11
Motion Ex. C, Defendants’ First Amended Rule 26(a)(1) Initial Disclosures (“Defendants’ Initial Disclosures”),
Section 1.
10
9603403.14
Mr. Burrows co-founded Orbis with Mr. Steele and was involved in briefings regarding
the research project relating to the defamatory statements, the content of the research, and the
engagement of Orbis for this research project. Defendants have identified Mr. Burrows as an
individual likely to have information relevant to this Action and Defendants’ claims and
defenses, such as the “relevant conduct of Orbis and Christopher Steele; Christopher Steele,
including his experience, work, process, and engagement by Defendants.” 12
Orbis is the intelligence gathering firm founded by Mr. Steele and Mr. Burrows which
was retained by Defendants in 2016 and which produced CIR 112, including the statements
about Plaintiffs at issue in this Action. Defendants acknowledge engaging Orbis to “look into
then-candidate Trump’s activities in Russia, in support of Defendants’ ongoing research
activities” and that Mr. Steele and Mr. Burrows were some of the people at Orbis with whom
“Defendants mainly communicated.” 13 Orbis is likely to have information and documentary
evidence relevant to the issues in this Action, including the engagement of Orbis, the research
conducted, the compilation of CIR 112, and the statements about Plaintiffs at issue in this
Action.
Edward Baumgartner co-founded the U.K. based research and intelligence firm Edward
Austin and assisted Fusion with the 2016 research at issue in this Action. Defendants have
formally identified Mr. Baumgartner as an individual likely to have information relevant to this
Action and Defendants’ claims and defenses, including the “research related to matters in CIR
112.” 14
12
Motion Ex. C, Defendants’ Initial Disclosures, Section 1.
13
Motion Ex. F, Defendants’ Answer to Interrogatory No. 12.
14
11
9603403.14
Sir Andrew Wood is a former British diplomat with or to whom Mr. Steele discussed or
transmitted the research at issue in this Action in 2016. Defendants have formally identified Sir
Andrew Wood as an individual likely to have information relevant to this Action and
Defendants’ claims and defenses, including the “receipt and delivery of CIR 112.” 15
SUBJECTS FOR ORAL EXAMINATION AND REQUESTS FOR PRODUCTION OF

DOCUMENTARY EVIDENCE
The District Court requests that Christopher Steele be ordered to attend for examination
to give evidence about the matters identified in Attachment A hereto and be ordered to produce
documentary evidence responsive to the requests identified in Attachment B hereto.
The District Court requests that Orbis Business Intelligence Ltd. be ordered to produce
documentary evidence responsive to the requests identified in Attachment C hereto.
The District Court requests that Christopher Burrows be ordered to attend for
examination to give evidence about the matters identified in Attachment D hereto.
The District Court requests that Edward Baumgartner be ordered to attend for
examination to give evidence about the matters identified in Attachment E hereto and be
ordered to produce documentary evidence responsive to the requests identified in Attachment F
hereto.
The District Court requests that Sir Andrew Wood be ordered to attend for examination
to give evidence about the matters identified in Attachment G hereto and be ordered to produce
documentary evidence responsive to the requests identified in Attachment H hereto.
For the reasons set forth in the Plaintiffs’ Motion in Support of Request for International
Judicial Assistance, the District Court believes that the witnesses (whose contact details are
15
12
9603403.14
given below) will be able to provide documentary evidence and testimony directly relevant to the
main issues between the parties in the Action and without which the ends of justice could not be
properly met. 16 The District Court believes that this information is not available from any other
source.
7. Evidence to be obtained: Plaintiffs seek oral testimony from Christopher Steele,

Christopher Burrows, Edward Baumgartner, and Sir
Andrew Wood. These individuals are not parties to the
Action and the Plaintiffs are not seeking any relief
against any of these witnesses.
Plaintiffs seek documentary evidence from Christopher

Steele, Edward Baumgartner, Sir Andrew Wood, and
Orbis Business Intelligence Ltd.
8. Identity and addresses of Christopher Steele

persons to be examined: c/o Orbis Business Intelligence Ltd., located at
9-11 Grosvenor Gardens, London SW1W
0BD
Christopher Burrows
c/o Orbis Business Intelligence Ltd., located at
9-11 Grosvenor Gardens, London SW1W
0BD
Edward Baumgartner
c/o Edward Austin Limited
4 Old Park Lane
London W1K 1QW
Sir Andrew Wood

c/o The Royal Institute of International Affairs
Chatham House
10 St James's Square
London SW1Y 4LE
United Kingdom
16
The term “documents” shall have the same broad meaning and scope as given to these terms in or pursuant to the
U.S. Federal Rules of Civil Procedure and applicable law, including (but not limited to) hard copy documents and
files as well electronic or computerized data, e-mails, text messages, etc. The term “communications” shall mean
the transmittal of data or information by any means, including (but not limited to) meetings, conversations,
discussions, documents, correspondence, messages, text messages, e-mails, notes, WhatsApp messages, Slack
messages, Skype messages, or other means of transmittal.
13
9603403.14
9. Subject matter about The subject matter for the examination of the relevant
which the witnesses will witnesses are itemized in Attachments A, D, E, and G.
be examined:
10. Documents or other Plaintiffs request that the relevant witnesses produce to
property to be inspected the Examiner and to Plaintiffs’ Counsel, no later than 7
calendar days before the date on which the Examination
is due to commence the documents set out under
Attachments B, C, F and H.
11. Any requirement that The witnesses should be examined under oath or
the evidence be given on affirmation or in the alternative should be instructed of
oath or affirmation and the consequences of giving untruthful and false answers
any specific form to be under the laws of England and Wales.
used:
12. Special methods or procedures to be followed:
The District Court respectfully requests the following with respect to the oral testimony
and production of documents being sought:
(1) that the High Court appoint an English Examiner for the purpose of compelling oral
testimony for use at trial from English witnesses;
(2) that the parties’ representatives or their designees, a court reporter, and a
videographer be permitted to be present during the examination either physically or
via remote or virtual means; that the representatives or designees be permitted to
examine and cross-examine the witnesses directly; and that a court reporter and a
videographer be permitted to make a verbatim record of the proceedings; and
(3) in connection with the taking of testimony of the witnesses, Plaintiffs have
permission to refer the witnesses to documents previously produced or available in
the Action.
14
9603403.14
13. Request for notification It is requested that testimony be taken at such place,
of the times and place for date or time as ordered by the Senior Master and/or as
the execution of the otherwise scheduled by the representatives of the
Request and identity of Plaintiffs and/or as otherwise agreed to by the
the person to be notified: witnesses and the respective representatives of the
parties.
14. Request for attendance or None.

participation of judicial
personnel of the
requesting authority at
the execution of the
Letter of Request:
15. Specification of privilege In relation to claims for privilege under the laws of the
or duty to refuse to give United States or the laws of England and Wales, regard
evidence under the laws shall be had to section 3 of the Evidence (Proceedings
of the State of origin: in Other Jurisdictions) Act 1975.
Under the laws of the United States, a party has a

privilege to refuse to give evidence if the evidence
discloses a confidential communication between that
party and an attorney for that party that was made for
the purpose of obtaining legal advice.
Parties also enjoy limited privileges on other grounds

not expected to be relevant here such as
communications between physician and patient,
psychotherapist and patient, husband and wife, or
clergy and penitent.
U.S. law also recognizes a privilege against criminal

self-incrimination.
Outside the strict area of privilege, certain limited

immunities are available that may place restrictions on
the giving of evidence, such as the limited protection of
documents created as the work product of attorneys
during or in anticipation of litigation.
15
9603403.14
16. Fees and costs: The fees and costs incurred which are reimbursable
under the second paragraph of Article 14 or under
Article 26 of the Hague Convention will be borne by
Plaintiffs.
17. Date of Request: _____________________, 2020
18. Signature and seal of the

Requesting Authority: UNITED STATES OF AMERICA
United States District Court for the District of
Columbia
__________________________________
By: Honorable Richard J. Leon
16
9603403.14
ATTACHMENT A
Proposed Subjects for Oral Examination of Christopher Steele
1. In general terms, Mr. Steele’s educational background, employment history, professional

qualifications and personal preparation for the examination (including contacts with the
parties, their lawyers, insurers, or representatives), excluding any privileged
2. Retention of Mr. Steele and/or Orbis in 2016 by Fusion relating to CIR 112 and the scope
and purpose of the retention.
3. Communications and meetings in 2016 and 2017 between Mr. Steele and Defendants
Glenn Simpson or Fusion or any Fusion sub-contractors regarding Plaintiffs, Alfa, CIR
112, or the statements about Plaintiffs in CIR 112.
4. Communications and meetings in 2016 and 2017 between Mr. Steele and Jonathan Winer
regarding Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in CIR 112.
5. Communications and meetings in 2016 and 2017 between Mr. Steele and reporters or
news or media organizations regarding Plaintiffs, Alfa, CIR 112, or the statements about
6. Communications and meetings in 2016 and 2017 between Mr. Steele and David Kramer
regarding Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in CIR 112.
7. The drafting and compilation in 2016 of CIR 112 and its promotion.
8. Delivery, transmission, or disclosure of CIR 112 in 2016 and 2017 to other persons or
entities, including Defendants, Mr. Kramer, Mr. Winer, reporters and members of the
media.
9. The steps taken by Mr. Steele, Orbis, or Defendants to corroborate, verify or investigate
the information and statements about Plaintiffs in CIR 112.
10. The destruction, return, or non-retention of the following documents: (a) CIR 112,
including work product, memoranda, source information, drafts or analysis relating to
CIR 112; (b) communications between Mr. Steele and Defendants Simpson or Fusion in
respect to CIR 112; and (c) engagement agreements between Mr. Steele and/or Orbis on
one hand and Fusion on the other which govern the creation or promotion of CIR 112.
11. Communications and meetings in 2016 and 2017 between Mr. Steele and Igor
Danchenko regarding Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in CIR
112.
17
9603403.14
ATTACHMENT B
Proposed Requests for Production of Documentary Evidence from Christopher Steele
1. Documents setting out the terms of Orbis’s and/or Mr. Steele’s engagement with or
retention by Fusion in connection with the compilation or preparation of CIR 112 and its
promotion.
2. Documents setting out the scope and purpose of the work that Mr. Steele and Orbis were
to perform in connection with the compilation or preparation of CIR 112 and its
promotion.
3. Communications between Mr. Steele and Defendants Glenn Simpson or Fusion

(including documents referencing or referenced in such communications) regarding
Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in CIR 112, within the period
01 April 2016 to 03 October 2017.
4. Communications between Mr. Steele and Jonathan Winer (including documents

referencing or referenced in such communications) regarding Plaintiffs, Alfa, CIR 112, or
the statements about Plaintiffs in CIR 112, within the period 01 September 2016 to 10
January 2017.
5. Communications within the period 01 September 2016 to 10 January 2017 (including

Mr. Winer relating to meetings regarding Plaintiffs, Alfa, CIR 112, or the statements
about Plaintiffs in CIR 112, including the meeting between Mr. Steele and U.S.
Department of State officials and Mr. Winer on or about 11 October 2016.

the New York Times, the New Yorker, the Washington Post, Yahoo! News, CNN, Mother
Jones, and/or BuzzFeed, relating to meetings regarding Plaintiffs, Alfa, CIR 112, or the
statements about Plaintiffs in CIR 112, including the meeting between Mr. Steele and
Michael Isikoff and Jane Mayer at the Tabard Inn on or about 22 September 2016.

the New York Times, the New Yorker, the Washington Post, Yahoo! News, CNN, Mother
Jones, and/or BuzzFeed regarding Plaintiffs, Alfa, CIR 112, or the statements about
8. Communications (including documents referencing or referenced in such

communications) between Mr. Steele and David Corn of Mother Jones via Skype on 31
October 2016 regarding Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in
CIR 112.
18
9603403.14

David Kramer regarding Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in
CIR 112, including text messages or other types of messages between Mr. Steele and Mr.
Kramer on or about 29 December 2016.
10. Documents within the period 01 July 2016 to 10 January 2017 relating to the drafting and
compilation of CIR 112; notes, research, investigative files used in the drafting of CIR
112; and drafts or different versions of CIR 112.
Defendants, Mr. Kramer, Mr. Winer, reporters and members of the media, or others
12. Communications within the period 01 July 2016 to 10 January 2017 (including
Defendants, Mr. Kramer, Mr. Winer, reporters and members of the media, or others
concerning the steps taken by Mr. Steele, Orbis, or Defendants to corroborate, verify, or
investigate the information and statements about Plaintiffs in CIR 112.
13. Documents concerning the destruction, return, or non-retention of documents within the
period 01 July 2016 to the present in respect to: (a) CIR 112, including work product,
memoranda, source information, drafts or analysis relating thereto; (b) communications
between Mr. Steele and Defendants Simpson or Fusion in respect to CIR 112; and (c)
engagement agreements between Orbis and/or Mr. Steele on one hand and Fusion on the
other which govern the creation or promotion of CIR 112.
14. Communications within the period 01 April 2016 to 03 October 2017 (including
Igor Danchenko regarding Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in
CIR 112.
19
9603403.14
ATTACHMENT C
Proposed Requests for Production of Documentary Evidence from Orbis Business

Intelligence Ltd.
1. Documents setting out the terms of Orbis’s and/or Mr. Steele’s engagement with or
retention by Fusion in connection with the compilation or preparation of CIR 112 and its
promotion.
2. Documents setting out the scope and purpose of the work that Orbis and Mr. Steele were
to perform in connection with the compilation or preparation of CIR 112 and its
promotion.
3. Communications between Orbis or Mr. Steele and Defendants Glenn Simpson or Fusion
(including documents referencing or referenced in such communications) regarding
Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in CIR 112, within the period
01 April 2016 to 03 October 2017.
4. Communications between Orbis or Mr. Steele and Jonathan Winer (including documents
the statements about Plaintiffs in CIR 112, within the period 01 September 2016 to 10
January 2017.

documents referencing or referenced in such communications) between Orbis or Mr.
Steele and Mr. Winer relating to meetings regarding Plaintiffs, Alfa, CIR 112, or the
statements about Plaintiffs in CIR 112, including the meeting between Mr. Steele and
U.S. Department of State officials and Mr. Winer on or about 11 October 2016.

Steele and the New York Times, the New Yorker, the Washington Post, Yahoo! News,
CNN, Mother Jones and/or BuzzFeed, relating to meetings regarding Plaintiffs, Alfa, CIR
112, or the statements about Plaintiffs in CIR 112, including the meeting between Mr.
Steele and Michael Isikoff and Jane Mayer at the Tabard Inn on or about 22 September
2016.

Steele and the New York Times, the New Yorker, the Washington Post, Yahoo! News,
CNN, Mother Jones, and/or BuzzFeed regarding Plaintiffs, Alfa, CIR 112, or the
statements about Plaintiffs in CIR 112.
8. Communications (including documents referencing or referenced in such
20
9603403.14
communications) between Orbis or Mr. Steele and David Corn of Mother Jones via
Skype on 31 October 2016 regarding Plaintiffs, Alfa, CIR 112, or the statements about

Steele and David Kramer regarding Plaintiffs, Alfa, CIR 112, or the statements about
Plaintiffs in CIR 112, including text messages or other types of messages between Mr.
Steele and Mr. Kramer on or about 29 December 2016.
10. Documents within the period 01 July 2016 to 10 January 2017 relating to the drafting and
compilation of CIR 112; notes, research, investigative files used in the drafting of CIR
112; and drafts or different versions of CIR 112.
Steele and Defendants, Mr. Kramer, Mr. Winer, reporters and members of the media, or
others regarding the delivery, transmission, or disclosure of CIR 112.
12. Communications within the period 01 July 2016 to 10 January 2017 (including
Steele and Defendants, Mr. Kramer, Mr. Winer, reporters and members of the media, or
others concerning the steps taken by Mr. Steele, Orbis, or Defendants to corroborate,
verify, or investigate the information and statements about Plaintiffs in CIR 112.
13. Documents concerning the destruction, return, or non-retention of documents within the
period 01 September 2016 to the present in respect to: (a) CIR 112, including work
product, memoranda, source information, drafts or analysis relating thereto; (b)
communications between Orbis or Mr. Steele and Defendants Simpson or Fusion in
respect to CIR 112; and (c) engagement agreements between Orbis and/or Mr. Steele on
one hand and Fusion on the other which govern the creation or promotion of CIR 112.
21
9603403.14
ATTACHMENT D
Proposed Subjects for Oral Examination of Christopher Burrows
1. In general terms, Mr. Burrows’s educational background, employment history,

professional qualifications and personal preparation for the examination (including
contacts with the parties, their lawyers, insurers, or representatives), excluding any
privileged communications or confidential details regarding any government service.
2. The drafting and compilation in 2016 of CIR 112 and its promotion.
3. The destruction, return, or non-retention of the following documents: (a) CIR 112,
including work product, memoranda, source information, drafts or analysis relating to
CIR 112; (b) communications with Defendants Glenn Simpson or Fusion in respect to
CIR 112; and (c) engagement agreements between Orbis and/or Mr. Steele on one hand
and Fusion on the other which govern the creation or promotion of CIR 112.
4. Delivery, transmission, or disclosure of CIR 112 in 2016 to other persons or entities,

including Defendants, David Kramer, Jonathan Winer, reporters and members of the
media.
5. The steps taken by Mr. Burrows, Mr. Steele, Orbis, or Defendants to corroborate, verify
or investigate the information and statements about Plaintiffs in CIR 112.
22
9603403.14
ATTACHMENT E
Proposed Subjects for Oral Examination of Edward Baumgartner
1. In general terms, Mr. Baumgartner’s educational background, employment history,

2. The nature and terms of Mr. Baumgartner’s, and/or his firm’s, engagement by Fusion in
2016 relating to Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in CIR 112,
and the scope and purpose of the engagement.
3. Mr. Baumgartner’s research regarding Plaintiffs, Alfa, CIR 112, or the statements about
4. Preparation of Mr. Baumgartner’s report titled “ALFA Dossier Open Sources.”
5. Communications in 2016 or 2017 between Mr. Baumgartner and Defendants Glenn

Simpson or Fusion regarding the report titled “ALFA Dossier Open Sources.”
6. Communications in 2016 or 2017 between Mr. Baumgartner and Defendants Simpson or

Fusion regarding Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in CIR 112.
23
9603403.14
ATTACHMENT F
Proposed Requests for Production of Documentary Evidence from Edward Baumgartner
1. Documents setting out the terms and scope of Mr. Baumgartner’s engagement by Fusion
relating to Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in CIR 112 or its
promotion.
2. Documents within the period 01 April 2016 to 03 October 2017 related to the preparation
of the report titled “ALFA Dossier Open Sources.”
3. Communications within the period 01 April 2016 to 03 October 2017 between Mr.
Baumgartner and Defendants Glenn Simpson or Fusion regarding the report titled
“ALFA Dossier Open Sources.”
4. Communications within the period 01 April 2016 to 03 October 2017 between Mr.
Baumgartner and Defendants Simpson or Fusion regarding Plaintiffs, Alfa, CIR 112, or
the statements about Plaintiffs in CIR 112.
5. Documents regarding Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in CIR
112, within the period 01 April 2016 to 03 October 2017.
24
9603403.14
ATTACHMENT G
Proposed Subjects for Oral Examination of Sir Andrew Wood
1. In general terms, Sir Andrew Wood’s educational background, employment history,

2. Communications in 2016 and 2017 between Sir Andrew Wood and Christopher Steele
regarding Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in CIR 112,
including in September 2016 around the time that Mr. Steele and Orbis transmitted CIR
112 to Fusion.
3. Communications and meetings in 2016 and 2017 between Sir Andrew Wood and David
Kramer or U.S. Senator John McCain regarding Plaintiffs, Alfa, CIR 112, or the
statements about Plaintiffs in CIR 112, including the meetings with Mr. Kramer and
4. Communications and meetings between Mr. Kramer and Mr. Steele in 2016 and 2017
regarding Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in CIR 112,
including the meeting between Mr. Kramer and Mr. Steele in London in November 2016
which Sir Andrew Wood arranged.
5. The steps taken by Sir Andrew Wood, Mr. Steele, Orbis, or Defendants to corroborate,
verify or investigate the information and statements about Plaintiffs in CIR 112.
25
9603403.14
ATTACHMENT H
Proposed Requests for Production of Documentary Evidence from Sir Andrew Wood
1. Communications within the period 01 September 2016 to 10 January 2017 between Sir
Andrew Wood and Mr. Steele (including documents referencing or referenced in such
communications) regarding Plaintiffs, Alfa, CIR 112, or the statements about Plaintiffs in
CIR 112, including in September 2016 around the time that Mr. Steele and Orbis
transmitted CIR 112 to Defendant Fusion and relating to the meeting between Mr.
Kramer and Mr. Steele in London in November 2016.
2. Communications within the period 01 September 2016 to 10 January 2017 between Sir
Andrew Wood and David Kramer or U.S. Senator John McCain (including documents
the statements about Plaintiffs in CIR 112, including the meetings with Mr. Kramer and

documents referencing or referenced in such communications) between Sir Andrew
Wood and Mr. Steele, Mr. Kramer, Orbis, or Defendants concerning the steps taken by
Sir Andrew Wood, Mr. Steele, Orbis, or Defendants to corroborate, verify, or investigate
the information and statements about Plaintiffs in CIR 112.
26
9603403.14

Fridman, Aven, & Khan Motion For Issuance of Letter of Request For International Judicial Assistance

Hochgeladen von

Dokumentinformationen

Originaltitel

Copyright

Verfügbare Formate

Dieses Dokument teilen

Dokument teilen oder einbetten

Freigabeoptionen

Stufen Sie dieses Dokument als nützlich ein?

Sind diese Inhalte unangemessen?

Copyright:

Verfügbare Formate

Fridman, Aven, & Khan Motion For Issuance of Letter of Request For International Judicial Assistance

Hochgeladen von

Copyright:

Verfügbare Formate

Case 1:17-cv-02041-RJL Document 90 Filed 08/04/20 Page 1 of 3

UNITED STATES DISTRICT COURT

Taking of Evidence Abroad in Civil or Commercial Matters (the “Hague Convention”), 28

Declaration of Alan S. Lewis, accompany this motion.

requested, and otherwise take no position on the motion.

Dated: Washington, D.C.

/s/ Kim Sperduto

Kim Sperduto (DC Bar No. 416127)

Attorneys for Plaintiffs

/s/ Kim Sperduto

UNITED STATES DISTRICT COURT

I. THE LEGAL STANDARD

in a foreign jurisdiction, application of the Hague [Evidence] Convention, which encompasses

principles of international comity, is virtually compulsory.” Tulip Computers Int'l B. V. v. Dell

Computer Corp., 254 F. Supp. 2d 469, 474 (D. Del. 2003).

located in a foreign jurisdiction—the United Kingdom—which is a party to the Hague

4. 28 U.S.C. § 1781(b) also provides that letters of request may be transmitted

LEXIS 201347 at *13.

motion be granted and issue the accompanying Letter of Request.

II. BACKGROUND REGARDING NEED FOR TESTIMONY AND EVIDENCE

7. The defamatory statements were in a two-page memorandum or “report” labeled

“Dossier” (referred to herein as the “Dossier” or the “reports”).

8. In spite of the Trump-focused nature of the Defendants’ research which was

Plaintiffs in the following ways:

a. The heading of CIR 112, “RUSSIA/US PRESIDENTIAL ELECTION:

KREMLIN-ALPHA GROUP COOPERATION,” coupled with Plaintiffs and Alfa 4 being

Kremlin-orchestrated illegal campaign to influence the outcome of the 2016 U.S.

b. CIR 112 also states: “Significant favours continued to be done in both

sentence defames Plaintiffs by accusing them of maintaining a relationship with Mr.

Putin that includes bribery and corruption.

c. CIR 112 also contains the following defamatory passage:

during the 1990s GOVORUN had been Head of Government

The defamatory meaning of the first sentence of this passage is an accusation of

misleading as a matter of fact.” 6

Plaintiffs have represented that they do not seek disclosure of communications or

disclosure of evidence for use in this U.S. proceeding. 9

Disclosures”), Section 1).

experience, work, process, and engagement by Defendants.” Ex. C, Defendants’ Initial

to “look into then-candidate Trump’s activities in Russia, in support of Defendants’ ongoing

14. Edward Baumgartner is the co-founder of the U.K.-based research and

claims and defenses, specifically:

Relevant conduct of Plaintiffs; Plaintiffs’ roles in the business

Ex. C, Defendants’ Initial Disclosures, Section 1.

and delivery of CIR 112.” 17

basis of such privilege claims.

each, is set forth below.

III. PLAINTIFFS’ REQUESTS FOR ORAL EXAMINATION AND THE

each, are set forth below:

No. 1: In general terms, Mr. Steele’s educational background, employment history,

context to his qualifications and credibility as a witness.

candidate Trump’s activities in Russia, in support of Defendants’ ongoing research activities,”

transmitted CIR 112 to Defendants and others.

sourcing for the Dossier (which included CIR 112). 21

relevant in this Action. See No. 3 above, supra.

Defendant Fusion, to discuss the election-related research findings. 24 Defendants acknowledge

parties in 2016. Ex. F, Defendants’ Answer to Interrogatory No. 9. In addition, according to

recklessly—relevant issues in this Action.

Additionally, in their motion to dismiss, Defendants claimed that any briefing to

with reporters, or news or media organizations.

meetings and communications).

Relevance: Defendants acknowledge engaging Orbis, which Mr. Steele co-founded, to

“look into then-candidate Trump’s activities in Russia, in support of Defendants’ ongoing

in publication of such statements). In addition, Department of Justice Inspector General Michael